Argentina: AFIP extends the deadline for beneficial ownership declaration
On 22 October 2020, the Tax Administration (AFIP) published General Resolution 4839/2020 of 22 October 2020 providing further relief from the beneficial ownership declaration for 2019 and disclosures on financial and non-financial trusts introduced
See MoreECJ: Ruling on Transfer Pricing Treatment of Bank Transfers Between Branch and Parent
On 8 October 2020 the European Court of Justice (ECJ) ruled on Romania’s transfer pricing rules in relation to bank transfers from a branch to a head office that is located in another EU Member State. Impresa Pizzarotti concluded two loan
See MoreCzech Republic: Deputies agrees with the postponement of the electronic registration
On 16 October 2020, the deputies approved the proposal of the Ministry of Finance to postpone all four phases of the electronic registration of sales until 1 January 2023. The amendment to the Act on the Registration of Sales is now heading to the
See MoreSouth Korea: NTS releases updated MAP guidance
On 20 October 2020, South Korea's National Tax Service (NTS) has released updated Mutual Agreement Procedure (MAP) guidance on the official website. The guidance prescribes the following key areas: Overview of a Mutual Agreement Procedure
See MorePeru announces agreement for the exchange of financial account information
On 21 October 2020, the Peruvian tax authorities has announced that they will start the CRS Multilateral Competent Authority Agreement (CRS MCAA), the agreement for implementing the automatic exchange of financial account information under the
See MoreAustria: Finance Ministry publishes final guide regarding DAC6 reporting obligations
On 21 October 2020, the Finance Ministry published final guidance regarding the reporting requirement of cross border arrangements (DAC6). This final guide covers the definition of terms, reportable arrangements, hallmarks and main benefit test,
See MoreIreland: Finance Minister publishes Finance Bill 2020
On 22 October 2020, the Finance Minister, Paschal Donohoe TD, published Finance Bill 2020 following Cabinet approval at the Government meeting. The Bill underpins the Government’s support for the economy in the face of Covid-19 pandemic and the
See MoreFrance: Finance Minister announces to delay DST payments up to December 2020
The Minister of Finance, Bruno Le Maire, has recently declared that France intends to collect the country's digital services tax in December 2020, which was due in April and October 2020. The digital service tax in France will apply on the
See MoreAustria signs MAP agreement with Sweden
On 16 October 2020, the Finance Ministry of Austria announced that Austria signed an agreement regarding the implementation of agreements concluded on the basis of Article 22 (Mutual Agreement Procedure) with Sweden. The agreement effects from 6
See MoreSpain gazettes the law for digital services tax and financial transactions tax
On 16 October 2020, the Spanish Official Gazette published the Laws Nos. 4/2020 and 5/2020, implementing a digital services tax and a financial transactions tax. The law includes a 3 % tax on digital services including online advertising, online
See MoreQatar introduces new process for tax filing
The General Tax Authority (GTA) launched a new online tax administration system called the Dhareeba portal in October 2020 and the process for making submissions via the previous system is no longer effective. As a result, the previous process used
See MoreCosta Rica issues resolution on request for increased interest deduction limits
On October 15, 2020, Costa Rica published Resolution DGT-R-0032-2020, which outlines the application process for the taxpayer to increase the maximum deduction limit for net interest expense. The restriction on the deduction of interest expense was
See MoreIndia issues notification on transfer pricing tolerance range for 2019–20
On 19 October 2020, India’s Central Board of Direct Taxes has released the Notification No. 83/2020 setting the arm’s length pricing variation limit for assessment year 2020-21. Accordingly, the variation between the arm’s length price
See MoreArgentina: AFIP provides additional suspension regarding inspections, assessments, appeals
In response to corona virus pandemic, on 13 October 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4835 of 13 October 2020, providing an additional suspension up to 25 October 2020 regarding inspections,
See MoreOECD: Batch of Peer Review Reports on Dispute Resolution Mechanisms
On 22 October 2020 the OECD released a further batch of stage 2 peer review reports on tax dispute resolution mechanisms under BEPS Action 14. The minimum standard under BEPS action 14 is concerned with improving tax dispute resolution
See MoreHungary: Parliament approves tax omnibus bill including CFC Rules
On 13 October 2020, the Hungarian parliament approved a Bill No. T/13258, to amend various taxation laws. The bill contains the following measures: Disallow company income tax exemptions to controlled foreign companies from EU blacklisted
See MoreCzech Republic: Supreme Court makes a decision regarding transfer pricing issues
Recently, the Supreme Administrative Court has issued a landmark decision for companies that have incentives to invest in older systems. The court confirmed that failure to meet the condition not to increase the tax base for calculating tax relief
See MoreThailand declares penalty relief for transfer pricing disclosure forms in response to Covid-19 pandemic
The Revenue Department of Thailand declared a reduction of the penalty from THB 200,000 to THB 5,000 for late submissions of the transfer pricing (TP) disclosure form due to Covid-19 pandemic. The reduced penalty is available for disclosure
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