Israel issues draft bill to amend transfer pricing documentation requirements
On 12 October 2020, the Israeli Tax Authority (ITA) published a draft bill for public consultation, proposing to amend Section 85A of the Income Tax Ordinance (ITO) and its regulations. The proposal incorporates the principles of the OECD’s
See MoreEcuador: Government delays MCAA on automatic exchange of financial information
On 29 September 2020, the Organization for Economic Co-operation and Development (OECD) published an update regarding signatories of the multilateral competent authority agreement (MCAA) on automatic exchange of financial account information and
See MoreDenmark: High Court makes a decision against tax authority’s TP approach
On 5 October 2020, the High Court made a decision on a case entitled “Denmark vs. Shoe Group A/S” against the tax administration’s transfer pricing (TP) approach. The tax administration of Denmark used various theories to claim that a
See MoreDenmark: National tax court clarifies TP documentation rules for intergroup companies
On 24 September 2020, the Danish Tax Administration published a Decision No. SKM2020.387.LSR, clarifying the transfer pricing documentation requirements for a change of business structure within a group company. The case concerns a Danish
See MoreBelgium: Further extension of deadline for CIT return and local file
On 12 October 2020, the Ministry of Finance declared further extension of the deadline for filing corporate income tax (CIT) return to 16 November 2020 for Assessment Year 2020. Previously, the corporate income tax returns filing deadline had been
See MoreZambia: MOF presents the budget for 2021 to the National Assembly
On 25 September 2020, the Minister of Finance (MOF) presented the budget for 2020 to the National Assembly. Under the budget the following important amendments to the Income Tax Act will take effect from 1 January 2021: Corporate tax
See MoreGermany: Lower house of Parliament approves BEPS MLI
On 8 October 2020, the German federal parliament (lower house) passed a law to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). After completion of the ratification
See MorePoland: Transfer pricing changes in recent tax law
On 29 September 2020, a draft bill amending the corporate income tax (CIT) laws was submitted to the lower house of the Polish parliament. The amendments include following proposals related to transfer pricing. Extends the application of the
See MoreOECD: Report on Blueprint for Pillar Two of Digital Economy Taxation
On 12 October 2020 the OECD introduced a report on the Pillar Two Blueprint on digital economy taxation. Pillar Two aims to ensure that large multinational enterprises pay a minimum level of tax regardless of the location of their headquarters
See MoreOECD: Report on Pillar One Blueprint on Digital Economy Taxation
On 12 October 2020 the OECD introduced a report on the Pillar One Blueprint on digital economy taxation. Pillar One consists of a new taxing right for market jurisdictions over a share of residual profit calculated at an MNE group or segment
See MoreOECD: Reports on Blueprints for Pillars One and Two of Digital Economy Tax Proposals
Following a meeting of the OECD’s Inclusive Framework on 8 and 9 October 2020 the OECD held a presentation on 12 October 2020 to introduce Blueprint reports on Pillar 1 and Pillar 2 of the proposals on taxation of the digital economy. Public
See MorePeru extends country-by-country report submissions deadline
On 25 September 2020, the Peruvian tax authority has published Resolution No. 000155-2020/SUNAT, through which the country-by-country (CbC) reports on multinational group entities are extended for the fiscal year 2019. SUNAT extend it until the
See MoreHong Kong: IRD updates CbC XML schema and user guide
On 6 October 2020, Inland Revenue Department of Hong Kong has published the updated CbC reports XML schema and user guide. The Department has developed a data schema in XML which is based on the CbC XML Schema issued by the OECD. The data schema
See MoreIsrael extends annual tax return deadline
On 30 September 2020, the Israeli Tax Authority (ITA) has declared an extension of the deadline for submitting annual tax returns. The release indicates that the deadline is extended to 31 October 2020 for the submission of returns through online
See MoreSpain: Finance Committee of Senate approves the draft bill for digital services tax
On 1 October 2020, the Finance Committee of the Spanish Senate passed the draft bills regarding digital services tax (DST) and financial transactions tax (FTT). The bill was approved by the Spanish Lower House of Parliament on 30 July
See MorePoland: Parliament approves a bill to amend various income tax rules
On 30 September 2020, the Polish lower house of Parliament (Sejm) approved a Bill No.642 amending various income tax rules for business. The measures of Bill No. 642 will apply from 1 January 2021. The bill includes a number of proposed tax
See MoreIndonesia: Directorate General of Taxation issues new regulations on APA
On 17 September 2020, the Indonesian Directorate General of Taxation posted online Regulation No. PER- 17/PJ/2020 regarding the procedures for completing applications, implementing, and evaluating an advance pricing agreement (APA). The
See MoreKazakhstan: BEPS MLI enters into force
On 29 September 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, MLI entered
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