Kenya publishes the law reversing the tax rates provided due to COVID 19
On 27 November 2020, the National Treasury has published the Tax Laws (Amendment) (No.2) Bill, 2020 (“the Bill”) in the Kenya Gazette Supplement No.216 (National Assembly Bills No.48). The law seeks to reverse the major tax concessions
See MoreNamibia deposits BEPS MLI ratification instrument
On 9 December 2020, Namibia deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI will enter into force for Namibia on 1 April
See MoreMalaysia: The Finance Bill 2020 includes transfer pricing measures
On 16 November 2020, Malaysia issued the Finance Bill 2020 (Bill No. DR 17/2020) including following proposals related to transfer pricing provision. Penalties for failure to prepare transfer pricing documentation There is currently no
See MoreGermany: Ministry of Finance publishes new transfer pricing guidance
On 3 December 2020, the Federal Ministry of Finance (BMF) has published the Administrative Principles 2020, which contain updated guidelines on audits / reviews of transfer prices between related parties and the responsibility of taxpayers to
See MoreSpain: Senate approves the law for the ratification of BEPS MLI
On 2 December 2020, the Spanish Senate adopted the law for the ratification of BEPS MLI. On 7 June 2017, Spain signed the Multilateral Instrument (MLI). Spain will need to deposit its ratification instrument to bring the MLI into force for its
See MoreDenmark: Government publishes an Act to set the timeline for filing TP documentation
On 9 December 2020, the Ministry of Taxation Officially published L 28 Proposal for a Law No. 1835 of 8 December 2020 to establish the timeline for filing transfer pricing (TP) documentation and amends the Corporation Tax Act and various other acts
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 MorePoland publishes law amending corporate income tax act
On 30 November 2020, the act amending the Corporate Income Tax Act was published in the Polish Journal of Laws and thus entered into force. The amendment introduces compliance of limited partnership having their management or registered office in
See MoreAustralia updates APA guidance
On 3 December 2020, the Australian Taxation Office (ATO) published an updated law administration practice statement about the advance pricing arrangements (APA) program. The updated guidance (PS LA 2015/4) reflects changes to the APA
See MoreDenmark: Parliament adopts a Law regarding transfer pricing
On 3 December 2020, the Parliament adopted the draft Bill No. L 28, which proposes to implement the OECD's recommendations on permanent establishment, so that the Danish rules are brought into line with the latest international standards. The
See MoreGermany publishes a law for the ratification of BEPS MLI
On 27 November 2020, Germany published the law in the Official Gazette to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Germany must now deposit its ratification
See MoreFinland: Tax authority publishes CbC reporting XML schema version 2.0
On 4 December 2020, the Finnish tax authority has updated its CbC reporting guidance concerning changes in the Country-by-Country (CbC) reporting XML schema to Version 2.0. Version 2.0 (Country-by-Country Reporting XML Schema 2.0) is released by
See MoreSri Lanka: IRD postpones Master file and CbC reporting requirements
According to the notice of 23 November 2020, considering the prevailing Covid-19 pandemic and the multiple requests made by the stakeholders to the Ministry of Finance, the requirements to submit the TP documentations of Master Files and Country by
See MoreIreland: Revenue updates CbC user guide
On 30 November 2020, the Irish Revenue published an eBrief 216/20 on a new Tax and Duty Manual Part 38-03-21, which provides details of the release of CbC User Guide Version 2.0 and CbC XML Schema Version 2.0, which will be in use from 1 February
See MoreMexico issues general tax rules on Mandatory Disclosure Rules (MDR)
On 18 November 2020, the Mexican Tax Administration (SAT) has issued general tax rules (GTR) for 2020. The GTR includes a new ‘chapter’ related to the mandatory reporting requirements for certain transactions. Mandatory Disclosure Rules (MDR)
See MoreMalta: CFR updates CRS and CbC XML schema and user guide
On 30 November 2020, the Maltese Commissioner for Revenue (CFR) notified that the cut-off date for the version change of the CRS and CbC XML schemas for any domestic reporting is 10 January 2021. Any CRS and CbC XML data files submitted after this
See MoreCanada: Finance Department introduces new GST/HST requirement for new DST
On 30 November 2020, the Finance Department published the Fall Economic Statement 2020 - Supporting Canadians and Fighting COVID-19, including prudent fiscal plan with proposed measures for a tax system for the digital economy. Under current rules,
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
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