France: Tax authorities update guidelines regarding DAC6 reporting obligations
On 25 November 2020, the tax authorities published updated guidance regarding reporting rules applicable to intermediaries as regards cross-border arrangements under the provisions of Council Directive (EU) 2018/822 (DAC6) and it provides
See MoreFrance: Finance Ministry sends notices for DST collection
On 25 November 2020, the Ministry of Finance announced that French tax authorities have begun sending notices to demand millions of euros from large digital companies or US technology groups as they push ahead with a new 3% digital services tax
See MoreBulgaria: Parliament passed the Budget Act 2021
On 26 November 2020, the Parliament passed conclusively the 2021 Budget Act, which will enter into force on 1 January 2021. In the transitional and final provisions, Parliament today voted on child benefits and on tax breaks for childcare. The
See MoreCroatia: Parliament approves draft Law to ratify BEPS MLI
On 25 November 2020, the Parliament approved the draft Law 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 into force
See MoreOECD and UNDP: Building tax capacity in Georgia
A case study by the OECD and UNDP published on 27 November 2020 focuses on capacity building work undertaken with the Georgian tax administration through the Tax Inspectors Without Borders (TIWB) initiative. The study notes that the practical
See MoreItaly publishes new guidelines for TP documentation
On 23 November 2020, the Italian tax authority published new guidelines for transfer pricing (TP) documentation that fully replace the previous guidelines of 2010. The new guidelines implement a Ministerial Decree of 14 May 2018 that established
See MoreSingapore extends deadline for TP documentation
In response to the Covid-19 pandemic, for this group of companies which faced genuine difficulties in preparing and e-Filing the YA 2020 Corporate Income Tax (CIT) Returns due to the COVID-19 situation, the IRAS would grant them a 1-month extension
See MoreEstonia: Parliament considers Bill to amend BEPS Multilateral Instrument (MLI)
On 10 November 2020, Estonia’s parliament (Riigikogu) has accepted for consideration Bill No. 286 SE, to amend a Law on the Ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit
See MoreBelgium: Guidance on the technological requirements of DAC6
On 23 November 2020, the Belgian tax authorities issued guidance on the technological requirements of DAC6 and the mandatory disclosure and reporting of certain cross-border arrangements. The guidance comprises a user guide describing the
See MoreChile deposits BEPS MLI ratification instrument
On 26 November 2020, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, Chile on 26
See MoreMorocco approves BEPS MLI
On 16 November 2020, the House of Representatives of Morocco approved the law for the ratification of the multilateral convention to implement double taxation agreement (DTA) related measures to prevent base erosion and profit shifting (MLI).
See MoreMalta: CFR issues DAC6 XML Schema and user guide
On 16 November 2020, the Maltese Commissioner for Revenue (CFR) has issued the DAC6 XML Schema (to be used for filing information in relation to reportable cross-border arrangements) and the DAC6 XML Schema user
See MoreUAE publishes new guidance on CbC reporting
On 2 November 2020, the Ministry of Finance of the United Arab Emirates (UAE) conducted a sessions on Cabinet Resolution No. 44 of 2020 with respect to the country-by-country (CbC) reporting requirements for multinational enterprise (MNE)
See MoreItaly publishes Decree on procedures for DAC6 Reporting
On 20 November 2020, the Italian Ministry of Finance issued a Decree containing technical rules and procedures for the implementation of the DAC6 reporting requirements introduced by Legislative Decree No. 100 of 30 July 2020. In accordance
See MoreGermany: Upper House of Parliament approves BEPS MLI
On 6 November 2020, the German upper house of parliament approved the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Germany signed the MLI on 7 June 2017 in
See MoreUS: Tax court issues its opinion in case of Coca-Cola Co. v. Commissioner
On 18 November 2020, the U.S. tax court issued its opinion in a case of Coca-Cola Co. v. Commissioner, 155 T.C. No. 10. The tax court decision upheld two IRS adjustments that had contributed to increasing Coca-Cola’s taxable income by more than
See MoreItaly publishes draft Budget for 2021
On 20 November 2020, the Italian Government published an updated version of the draft budget law for the year 2021, which is currently under discussion within the Italian Parliament. Following tax measures contained in the Draft Budget relate
See MoreMalaysia: IRBM issues updated tax audit framework for finance and insurance
The Inland Revenue Board of Malaysia (“IRBM”) has published an updated Tax Audit Framework for Finance and Insurance (“the Framework”) which revokes Tax Audit Framework - Finance and Insurance dated 1 Jun 2015. The Framework comes into
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