Turkey publishes transfer pricing General Communiqué No. 4
On 1 September 2020, the Turkish Revenue Administration has published transfer pricing General Communiqué No. 4 on disguised profit distribution in the Official Gazette No. 31231. The Communiqué explains information regarding new transfer pricing
See MoreMexico: Executive Branch submits 2021 economic proposal to Congress
On 8 September 2020, the Mexican Executive Branch has submitted Economic Package for fiscal year 2021 including a proposal of Tax Reform. The proposed 2021 Tax Law clarifies income tax law, value-added tax (VAT) law, and federal tax code. Tax key
See MoreArgentina: AFIP provides additional suspension regarding inspections, assessments, appeals
In response to corona virus pandemic, on 21 September 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4818 of 21 September 2020, providing an additional suspension up to 11 October 2020 regarding inspections,
See MoreCyprus: CbC reporting deadline is 31 December 2020
The deadline for multinational enterprise (MNE) groups to comply with the country-by-country (CbC) reporting and notification obligations in Cyprus is 31 December 2020 for the fiscal year 2019. CbC reports and notifications are submitted through
See MoreHong Kong: IRD commence TP documentation compliance reviews
In September 2020, the Hong Kong Inland Revenue Department (IRD) began conducting the first round of compliance reviews of the taxpayers' transfer pricing documentation and issuing requests for information in accordance with Section 51 (4) A and 51
See MoreUS: IRS releases final regulations on interest expense deduction limitation
On 14 September 2020, the US IRS published the final regulations for the business interest expense deduction limitation published in the Federal Register. The final regulations vary slightly from the document released on IRS.gov on July 28,
See MoreNetherlands: Budget proposals for FY 2021
On 15 September 2020, the Dutch government published the budget proposals for fiscal year 2021. The proposals are currently subject to the review and discussions by the Dutch Parliament and as such may be subject to amendments. The final version of
See MoreAlgeria: Government provides policy measures amid COVID-19 pandemic
Due to COVID-19 pandemic, the Government is tackling by an oriented policy and a number of measures dedicated particularly to small business and small and medium enterprises (SMEs). The measures are given below: Postponement of the annual tax
See MoreCanada: The Tax Court makes a decision in a case regarding transfer pricing dispute
On 27 August 2020, the Tax Court of Canada made a decision in a case, Canada vs AgraCity Ltd. and Saskatchewan Ltd., in favor of Candian company AgraCity Ltd. and related company, Saskatchewan Ltd. The AgraCity Canada had entered into a Services
See MoreIndonesia: DGT publishes reporting requirements for companies eligible for reduced rate
On 1 September 2020, the Directorate General of Taxation (DGT) of Indonesia has published Regulation No. 123/PMK.03/2020 which provides the forms and procedures to claim the 3% corporate tax rate reduction that was introduced in June 2020. Under
See MoreHong Kong: IRD extends the due dates for filing profits tax returns for 2019/20
On 9 September 2020, the Inland Revenue Department (IRD) of Hong Kong has published a Circular Letter to Tax Representatives extending the deadline for filing Profits Tax returns. Accordingly, the Inland Revenue Department decided to extend the
See MoreArgentina: AFIP amends tax regularization scheme to support all taxpayers
On 26 August 2020, the Federal Administration of Public Revenue (AFIP) Officially published Law 27562, which amends the tax regularization scheme and made this available for all taxpayers amid COVID-19 pandemic. The scheme was previously
See MoreThailand reduces transfer pricing penalty amid Covid-19 pandemic
On 9 September 2020, the Revenue Department of Thailand announced to reduce fine for the late submission of the annual transfer pricing disclosure from THB 200,000 to THB 5,000 due to the Covid-19 pandemic, provided that the transfer pricing
See MoreUS: IRS announces tax relief for tropical storm ‘Isaias’ victims in Puerto Rico
On 10 September 2020, the Internal Revenue Service (IRS) has announced tax relief for tropical storm ‘Isaias’ victims in Puerto Rico. IRS states that tax returns and makes tax payments for individual and business has been extended until 30
See MoreIndonesia: Tax agency issues regulation on MAP process
On 11 August 2020, the Indonesian Directorate General of Taxation posted online Regulation No. PER-16/PJ/2020, on the mutual agreement procedure (MAP) rules under DTAs. The regulation covers: 1) the scope and definition of MAPs; 2) the deadline
See MoreSingapore publishes transfer pricing guidance in response to the Covid-19 outbreak
On 8 September 2020, the Inland Revenue Authority of Singapore updated its website by including guidance regarding transfer pricing in response to the Covid-19 pandemic. The guidance is provided in a following question and answering
See MorePanama: Special tax regime for multinational companies
On 31 August 2020, Mr. Laurentino Cortizo, the president of Panama signed Law No. 159, introducing a new tax regime designed to encourage multinationals to establish and operate manufacturing services in Panama. The new law (EMMA) looking
See MoreCroatia: Finance Ministry publishes a draft Law to ratify BEPS MLI
The Finance Ministry published a draft Law for ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). Public consultation is required from the Ministry regarding the draft Law. Croatia must now deposit
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