Australia: ATO declares lodgment deferral for Local File, Master File, and CbC Report for FY 2019
The Australian Taxation Office (ATO) has issued a notice declaring a lodgment deferral for the Local file, Master file, and Country-by-Country (CbC) report for the year ended 31st December 2019. Significant Global Entities (SGEs) that have
See MoreSouth Africa: SARS extends the CbC filing deadline
On 12 November 2020, the South African Revenue Service (SARS) published a notice, which stated that the due date for submitting country-by-country (CbC) report is extended on the basis of some specified person. According to the notice, the
See MoreMalta: CFR publishes dispute resolution mechanisms
On 9 November 2020, the Maltese Commissioner for Revenue (CFR) has published new guidance regarding tax dispute resolution mechanisms. The guidance note provides a general overview of the European Union Dispute Resolution Mechanisms (Directive
See MoreArgentina: AFIP provides further delay on inspections, assessments, appeals
In response to corona virus pandemic, on 9 November 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4856 of 9 November 2020, providing an additional suspension up to 29 November 2020 regarding inspections,
See MoreIreland: Revenue publishes eBrief regarding DAC6 reporting update
On 3 November 2020, the Irish Revenue published an eBrief No. 200/20, which provides EU mandatory disclosure of reportable cross-border arrangements. On the similar day, the Revenue also published a Tax and Duty Manual, providing general
See MoreBelgium further extends Local file and CIT return filing deadline
On 12 November 2020, the Belgian Minister of Finance (MoF) announced a further extension of the filing corporate income tax (CIT) returns to 30 November 2020 for the Assessment Year 2020. Previously, the deadline for filing corporate income tax
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
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UK: Updated Statistics on Transfer Pricing and Diverted Profits Tax
On 12 November 2020 HMRC published updated statistics relating to transfer pricing and the diverted profits tax for 2019/20 (the year to 31 March 2020). In 2019/20 a total of 125 transfer pricing enquiries were settled, with an average
See MoreCroatia: Parliament approves draft Law to ratify BEPS MLI
On 5 November 2020, the Parliament approved the draft Bill No. PZ 59 for ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). Croatia must now deposit its ratification instrument to bring the MLI
See MoreSingapore declares simplified corporate tax filing process
On 5 November 2020, the Inland Revenue Authority of Singapore has announced the simplification of corporate tax filing for companies. Corporate Tax Filing Simplified for Companies: Simplified Corporate Income Tax Return for Small CompaniesNew
See MoreUS and Singapore sign agreement on exchange of CbC reports
On 4 November 2020, IRS published the updated page on CbC reporting jurisdiction status table. Accordingly, on 6 October 2020, U.S. and Singapore have entered into a CAA for the automatic exchange of CbC reports. Pursuant to the provisions of
See MoreGhana: Finance Minister submits new TP Regulations 2020 before Parliament
On 10 August 2020, Mr. Ken Ofori-Atta, the Minister of Finance of Ghana submitted new Transfer Pricing (TP) Regulations 2020 (L.I. 2412) before Parliament. Accordance to Article 11(7) of the Constitution of the Republic of Ghana,
See MoreArgentina: AFIP provides suspension on inspections, assessments, appeals
In response to corona virus pandemic, on 26 October 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4840 of 26 October 2020, providing an additional suspension up to 8 November 2020 regarding inspections,
See MoreU.S. and Germany sign agreement on exchange of CbC reports
On 4 November 2020, IRS published the updated information on CbC reporting jurisdiction status table. Accordingly, on 14 August 2020, U.S. and Germany sign an agreement on exchange of Country-by-Country reports. Each Competent Authority intends
See MorePanama deposits its instrument of ratification for the Multilateral BEPS Convention
On 5 November 2020, Panama has deposited its instrument of ratification for the Multilateral Convention to implement tax treaty related measures to prevent base erosion and profit shifting (Multilateral Convention or MLI), which now covers almost
See MoreTransfer Pricing Brief: November 2020
AustriaScope of transfer pricing rules: On 21 October 2020, the Finance Ministry published final guidance of cross border arrangements (DAC6) including definition of terms, reportable arrangements, hallmarks and main benefit test, deadlines for
See MoreSwitzerland: Federal Council adopts dispatch on Federal Act on implementation of international tax agreements
On 4 November 2020, the Swiss Federal Council adopted the dispatch on the Federal Act on the implementation of international tax agreements. With this proposal, the Federal Council is adapting the existing law to the changes made to international
See MoreOman: BEPS MLI in force
The Multilateral Convention to execute tax agreement related measures to prevent base erosion and profit shifting (MLI) entered into force for Oman on 1 November 2020. As regards the double taxation agreement (DTA) between Oman and the other
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