Mexico 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
See MorePeru: SUNAT extends CbC reports submissions deadline for FY 2017, 2018 and 2019
On 2 December 2020, the Peruvian tax authorities (SUNAT) has declared that the deadlines for the secondary local (Peruvian) filing of the country-by-country (CbC) reports for fiscal years (FY) 2017, 2018, and 2019 is 29 January 2021. The
See MoreSri Lanka: TP documentation requirement for domestic controlled transactions
According to the notice of 25 November 2020, under the Regulation 1 of the TP Gazette, transfer pricing regulations inter alia, are applicable to the local transactions made between associated enterprises (AE) as referred to in section 77 of the
See MoreArgentina: AFIP extends suspension on inspections, assessments, appeals
In response to corona virus pandemic, on 27 November 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4868/2020 of 27 November 2020, providing an extension of suspension up to 31 December 2020 regarding
See MoreTransfer Pricing Brief: December 2020
AustraliaCbC reporting requirement/Master File/Local File: The Australian Taxation Office (ATO) has issued a notice declaring a lodgment deferral until 29th January 2021 for the Local file, Master file, and Country-by-Country (CbC) report for the
See MoreIndonesia notifies the confirmation of the completion of its internal procedures for MLI
On 26 November 2020, the Republic of Indonesia deposited a notification confirming the completion of its internal procedures for the entry into effect of the provisions of BEPS MLI. Indonesia signed the agreement on 7 June 2017 and it became
See MoreKazakhstan deposits notifications on its tax agreements
On 27 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, on 26 November
See MoreFrance: 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
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