Germany: 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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US and Mexico renew competent authority agreement on Maquiladoras
On 16 November 2020, the Internal Revenue Service (IRS) announced that IRS and Mexico’s Servicio de Administración Tributaria (“SAT”) have agreed to renew the Qualified Maquiladora Approach Agreement (“QMA”), a coordination
See MoreOECD: Consultation on review of the minimum standard under BEPS Action 14
A consultation document issued by the OECD on 18 November 2020 invites input from interested parties on proposals for the 2020 review of the Action 14 minimum standard on making dispute resolution mechanisms more effective. A number of possible
See MoreSri Lanka: Budget for 2021
On 17 November 2020, Mr. Mangala Samaraweera, the Finance Minister of Sri Lanka presented Budget for 2021. Finance Minister stated that tax law will be amended where it will be mandatory for all Companies to file their taxes only on an
See MoreThailand publishes new transfer pricing regulation
On 6 November 2020, Mr. Apisak Tantivorawong, the Minister of Finance issued Ministerial Regulation No. 369, published in the official bulletin 2556. The regulation sets basic rules to be followed by the tax authority when evaluating transactions
See MoreSouth Africa: SARS publishes discussion paper regarding APAs
Recently, the South African Revenue Service (SARS) published a Discussion paper on Advance Pricing Agreements (APAs). Discussion Papers are published by National Treasury or SARS to obtain public comment on specific tax policy matters before draft
See MoreMalta further extends electronic filing deadline of CIT returns amid COVID-19
On 16 November 2020, Malta’s Commissioner for Revenue has notified that the electronic filing deadline for year of assessment 2020 tax returns in respect of companies having a 31 December 2019 accounting year-end is being further extended to 16
See MoreAustralia: ATO declares lodgment deferral for Local File, Master File, and CbC Report for FY 2019
The Australian Taxation Office (ATO) has issued a notice declaring a lodgment deferral for the Local file, Master file, and Country-by-Country (CbC) report for the year ended 31st December 2019. Significant Global Entities (SGEs) that have
See MoreSouth Africa: SARS extends the CbC filing deadline
On 12 November 2020, the South African Revenue Service (SARS) published a notice, which stated that the due date for submitting country-by-country (CbC) report is extended on the basis of some specified person. According to the notice, the
See MoreMalta: CFR publishes dispute resolution mechanisms
On 9 November 2020, the Maltese Commissioner for Revenue (CFR) has published new guidance regarding tax dispute resolution mechanisms. The guidance note provides a general overview of the European Union Dispute Resolution Mechanisms (Directive
See MoreArgentina: AFIP provides further delay on inspections, assessments, appeals
In response to corona virus pandemic, on 9 November 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4856 of 9 November 2020, providing an additional suspension up to 29 November 2020 regarding inspections,
See MoreIreland: Revenue publishes eBrief regarding DAC6 reporting update
On 3 November 2020, the Irish Revenue published an eBrief No. 200/20, which provides EU mandatory disclosure of reportable cross-border arrangements. On the similar day, the Revenue also published a Tax and Duty Manual, providing general
See MoreBelgium further extends Local file and CIT return filing deadline
On 12 November 2020, the Belgian Minister of Finance (MoF) announced a further extension of the filing corporate income tax (CIT) returns to 30 November 2020 for the Assessment Year 2020. Previously, the deadline for filing corporate income tax
See MoreVietnam: MoF issues new transfer pricing Decree
On 5 November 2020, the Vietnamese Ministry of Finance (MoF) has issued new transfer pricing Decree No. 132/2020/ND-CP. The new Decree replaces the existing Transfer Pricing (TP) regulations (Decree No. 20/2017/ND-CP) and provides the following new
See MoreUK: Updated Statistics on Transfer Pricing and Diverted Profits Tax
On 12 November 2020 HMRC published updated statistics relating to transfer pricing and the diverted profits tax for 2019/20 (the year to 31 March 2020). In 2019/20 a total of 125 transfer pricing enquiries were settled, with an average
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