Ireland: Finance Minister publishes a feedback on ATAD interest limitation rule
On 23 December 2020, the Finance Department published feedback statement, which considers the final ATAD measure, an Interest Limitation Rule, which will also be implemented in Finance Bill 2021. In Ireland, the general anti-abuse rule (GAAR) met
See MoreSweden: Parliament approved Budget for 2021
On 17 December 2020, the Swedish Parliament (Riksdag) has approved Budget for fiscal year 2021. The Budget includes the following key tax measures: Temporary tax reduction of 3.9% of the acquisition value of machinery and equipment
See MoreAustria: Parliament approves winter package due to COVID-19 pandemic
On 17 December 2020, the Parliament approved the COVID-19 Tax Measures Act. Recently, the Ministry of Finance has announced the draft winter package on tax measures for the coronavirus outbreak. The package includes the measures to introduce the
See MoreAustralia: ATO releases final guidance on related party loan
On 10 December 2020, the Australian Taxation Office (ATO) issued final transfer pricing guidance on interest-free loans between related parties, in “Schedule 3 – Interest-free loans” to the ATO’s financing Practical Compliance Guideline
See MorePeru: Tax Administration issues report on interest deduction limitations
On 10 November 2020, the Peruvian Tax Administration (SUNAT) has published Report No. 093-2020-SUNAT/7T0000 on its website, which clarifies the interest deduction limitations rules. Through the Report, SUNAT analyzes the application of the
See MoreVietnam: MoF issues new transfer pricing Decree
On 5 November 2020, the Vietnamese Ministry of Finance (MoF) has issued new transfer pricing Decree No. 132/2020/ND-CP. The new Decree replaces the existing Transfer Pricing (TP) regulations (Decree No. 20/2017/ND-CP) and provides the following new
See MoreIreland: Finance Minister publishes Finance Bill 2020
On 22 October 2020, the Finance Minister, Paschal Donohoe TD, published Finance Bill 2020 following Cabinet approval at the Government meeting. The Bill underpins the Government’s support for the economy in the face of Covid-19 pandemic and the
See MoreCosta Rica issues resolution on request for increased interest deduction limits
On October 15, 2020, Costa Rica published Resolution DGT-R-0032-2020, which outlines the application process for the taxpayer to increase the maximum deduction limit for net interest expense. The restriction on the deduction of interest expense was
See MoreSweden: Countermeasures in the tax area against non-cooperating jurisdictions
On 13 October 2020, the Swedish Ministry of Finance has issued a press release, where they confirm that a draft bill was submitted to the Parliament to restrict deductions for interest expenses paid to non-cooperative jurisdictions. The
See MoreZambia: MOF presents the budget for 2021 to the National Assembly
On 25 September 2020, the Minister of Finance (MOF) presented the budget for 2020 to the National Assembly. Under the budget the following important amendments to the Income Tax Act will take effect from 1 January 2021: Corporate tax
See MoreUS: IRS releases final regulations on interest expense deduction limitation
On 14 September 2020, the US IRS published the final regulations for the business interest expense deduction limitation published in the Federal Register. The final regulations vary slightly from the document released on IRS.gov on July 28,
See MoreNetherlands: Budget proposals for FY 2021
On 15 September 2020, the Dutch government published the budget proposals for fiscal year 2021. The proposals are currently subject to the review and discussions by the Dutch Parliament and as such may be subject to amendments. The final version of
See MoreAustralia: ATO clarifying the operation of hybrid mismatch rules
Australia's hybrid mismatch rules have been updated with a number of technical amendments in order to clarify and improve the rules' operation. In the 2019–20 Budget on 2 April 2019, the Australian government announced the measure Tax
See MoreMalta: Commissioner for Revenue issues ATAD implementation Guidelines
On 31 August 2020, the Maltese Commissioner for Revenue has issued Guidelines in relation to the Anti-Tax Avoidance Directives Implementation Regulations (ATAD) on its website. The guidelines on the ATAD Implementation Regulations were issued in
See MoreUS: IRS publishes additional guidance on base erosion and anti-abuse tax
On 1 September 2020, the Internal Revenue Service issued final regulations providing additional guidance on the base erosion and anti-abuse tax (BEAT). To limit profit-shifting, the Tax Cuts and Jobs Act (TCJA) added a new tax, the BEAT. The
See MoreAustralia: ATO finalized guidance on the arm’s length debt test
On 12 August 2020, the Australian Taxation Office (ATO) released its finalized practical guidance dealing with the application of the arm’s length debt test (ALDT) which applies as one of the options for determining deductibility of interest and
See MoreGreece: Parliament published two Laws to introduce various changes in transfer pricing context
On 31 July 2020 and on 29 July 2020, the Greek Parliament Officially published two Laws, L. 4714/2020 and L. 4712/2020 respectively regarding various sections of transfer pricing. The two Laws cover the following changes: Tax dispute Resolution
See MoreUS: IRS issues final regulations and other guidance on business interest expense deduction limitation
On 28 July 2020, the Internal Revenue Service issued final regulations regarding the provision of the Tax Cuts and Jobs Act that limits the deduction for business interest expense, including basic statutory amendments made by the CARES Act. For
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