Luxembourg: Tax Administration issues update guidance on DAC6 reporting
On 14 October 2020, the Luxembourg Tax Administration has issued updated guidelines concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) as per Council Directive (EU) 2018/822 of 25 May 2018. DAC6 is effective
See MoreOECD: Taxation of Virtual Currencies
On 12 October 2020 the OECD released a report on taxing virtual currencies that was prepared for the meeting of G20 Finance Ministers. The report looks at the tax treatment of virtual currencies, considering income tax, consumption tax and property
See MoreJordan ratifies BEPS multilateral convention (MLI)
On 29 September 2020, Jordan deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) with the OECD. The MLI will enter into force for Jordan
See MoreSweden: Countermeasures in the tax area against non-cooperating jurisdictions
On 13 October 2020, the Swedish Ministry of Finance has issued a press release, where they confirm that a draft bill was submitted to the Parliament to restrict deductions for interest expenses paid to non-cooperative jurisdictions. The
See MoreBelarus is set to join the Inclusive Framework on BEPS
On 14 October 2020, Belarus has published Resolution No. 590 on the National Legal Internet Portal, through which Belarus is set to join the Global Forum on Transparency and Exchange of Information for Tax Purposes. The decision was formalized in
See MoreOECD: Tax Talk Summarises Latest Tax Developments
In a Tax Talk on 12 October 2020 the OECD gave an update of recent developments. Digital Economy The OECD’s Inclusive Framework met on 8 and 9 October 2020 and Blueprint reports on Pillar 1 and Pillar 2 of the proposals on taxation of the
See MoreIsrael 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 More