Sweden: 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
See MoreVietnam: Government issues Decree increasing cap on deductible interest expenses
On 24 June 2020, the Vietnamese Government has issued Decree No. 68/2020/ND-CP amending and supplementing Clause 3, Article 8 of Decree 20/2017/ND-CP (Decree 68). On 14 July 2020, the Vietnam Ministry of Finance (MOF) has also issued Official
See MoreFinland publishes guidance on hybrid mismatch rules
On 3 July 2020, the tax authorities have published guidance no. VH/2738/00.01.00/2020 concerning the legislation on cross-border hybrid mismatches, transposing the hybrid mismatch rules, the EU Anti-Tax Avoidance Directive (ATAD) 2016/1164 and
See MoreIreland: Irish Revenue introduces new hybrid mismatch guide
On 8 July 2020, the Revenue published eBrief No. 137/20 on a new Tax and Duty Manual Part 35C-00-01, which provides an overview of the anti-hybrid rules that were introduced into Part 35C TCA 1997 by Finance Act 2019. This manual covers following
See MoreAustralia: Integrity rule law companion ruling finalized
In April 2019, Australian Taxation Office (ATO) released a draft Law Companion Ruling on the Organization for Economic Cooperation and Development (OECD) hybrid mismatch rules related to integrity rule. The ATO have now released draft LCR
See MoreGreece: Finance Ministry published a Bill regarding anti-hybrid rules for public consultation
On 7 July 2020, the Ministry of Finance published a draft bill related to the transposition of anti-hybrid rules for public consultation. This Bill includes a new article, Article 50 to amend the Article 66B and covers to the extent in where a
See MoreCyprus Gazettes EU Anti-Tax Avoidance Directive
After the partial adoption of the EU Anti-Tax Avoidance Directive (ATAD I) of 12 July 2016 in 2019, on 19 June 2020 the Parliament of Cyprus voted into law the remaining provisions of ATAD I, as well as the provisions of the EU ATAD II of
See MoreCyprus: House of Representatives passed the law to implement EU ATAD
On 19 June 2020, the Cyprus Parliament adopted the law to implement the provisions EU Anti-Tax Avoidance Directive (ATAD I) with respect to exit taxation rules, as well as, the provisions of the amending Directive (ATAD II) with respect to
See MorePoland: Parliament passes a law implementing ATADII & DAC 6
On 18 June 2020, the higher chamber of the parliament passed a bill implementing the rules related to hybrid mismatches with third countries (ATAD II) and completing the transposition of the DAC 6 rules in its domestic legislation. Under the
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