Hong Kong and Russia sign an agreement for the exchange of CbC report
On 3 September 2020, the Russian Federal Tax Service has announced that Hong Kong and Russia signed an agreement on the exchange of Country-by-Country (CbC) reports for the 2017 and 2018 reporting years. For reporting fiscal years beginning on or
See MorePhilippines: Committee on Ways and Means submits a Bill regarding DST services
On 18 August 2020, the Committee on Ways and Means submitted a Bill, House Bill No. 7425 to the House of Representatives, which would serve as a substitute Bill of all the previous bills on the digital transactions tax. The Bill proposed to impose
See MoreMalta: Commissioner for Revenue issues ATAD implementation Guidelines
On 31 August 2020, the Maltese Commissioner for Revenue has issued Guidelines in relation to the Anti-Tax Avoidance Directives Implementation Regulations (ATAD) on its website. The guidelines on the ATAD Implementation Regulations were issued in
See MoreGreece: Government publishes a Law amending APA rollback rules
On 31 July 2020, the Government Officially published Law 4714/2020, which amends the existing advance pricing agreement (APA) provisions. The new Law helps to comply with the minimum standard under Action 14 of the OECD’s base erosion and profit
See MorePoland clarifies the treatment of dividends under TP rules
On 6 August 2020, the Polish Ministry of Finance has issued a guidance on whether a dividend payment among related entities falls within the scope of the definition of a “controlled transaction” for transfer pricing purposes. The uncertainty
See MoreUS: IRS publishes additional guidance on base erosion and anti-abuse tax
On 1 September 2020, the Internal Revenue Service issued final regulations providing additional guidance on the base erosion and anti-abuse tax (BEAT). To limit profit-shifting, the Tax Cuts and Jobs Act (TCJA) added a new tax, the BEAT. The
See MoreTransfer Pricing Brief: September 2020
AustraliaFinancial transactions-Restriction on interest deduction: On 12 August 2020, the Australian Taxation Office (ATO) released its finalized practical guidance dealing with the application of the arm’s length debt test (ALDT) which applies
See MoreOECD: Tax Policy Reforms 2020
On 3 September 2020 the OECD issued Tax Policy Reforms 2020 setting out the reforms introduced by OECD countries and by Argentina, Indonesia and South Africa in the past year. This issue also includes China for the first time. The publication
See MoreSouth Korea: National Tax Service investigates MNEs tax evasion
On 27 August 2020, the South Korean National Tax Service has announced that it has initiated a tax audit on 21 multinational enterprises (MNEs) suspected of cross-border and committing tax evasion and 22 offshore tax evasion suspects, including
See MoreArgentina: AFIP announces additional suspension regarding inspections, assessments, appeals
On 18 August 2020, the Federal Administration of Public Revenue published General Resolution 4794 of 18 August 2020, which provides an additional postponement in case of inspections, assessments, appeals, reimbursements, other methods related to
See MoreOECD: Global Forum issues peer review reports on transparency and exchange of information
On 1 September 2020 the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes issued nine new second-round peer review reports containing details of their review and assessment of the compliance by nine jurisdictions
See MoreUN: Subcommittee considers article on taxation of automated digital services
The subcommittee on tax challenges of the digital economy of the UN Committee of Experts on International Cooperation in Tax Matters held a meeting from 25 to 27 August 2020. The subcommittee considered the proposed new Article 12B to the UN
See MoreEgypt: Parliament approves BEPS multilateral instrument (MLI)
On 18 August 2020, the Egyptian House of Representatives (Parliament of Egypt) has approved several presidential decrees on international agreements. Among the agreements, the Parliament has approved the Multilateral Convention to Implement Tax
See MoreNew Zealand: Inland Revenue releases guidance on transfer pricing amid COVID-19
Recently, New Zealand’s Inland (IR) Revenue has released guidance regarding practice issues for transfer pricing due to the COVID-19 pandemic. The COVID-19 pandemic has created an impact on specific sectors and businesses substantially. The
See MorePakistan: FBR approves the Audit Policy 2019
On 26 August 2020, the Pakistan Federal Board of Revenue (FBR) announced the approval of the Audit Policy 2019. The Audit Policy 2019 shall apply to persons or classes of persons falling under all or any of the three domestic Federal Tax Statutes
See MoreBrazil: Chamber of Deputies considers new draft Bill regarding digital service tax
On 19 August 2020, a Bill 218/2020, the social contribution on digital services (CSSD), was submitted and considered by the Chamber of Deputies, which provides the introduction of digital service tax (DST). Previously, On 4 May 2020, Mr. João
See MoreTaiwan: MOF announces draft amendments to transfer pricing guidelines
On 18 August 2020, Taiwan’s Ministry of Finance (MOF) has announced draft amendments to certain transfer pricing provisions based on chapter 6 of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The
See MoreEcuador: Reminder for the effective date of Vat law regarding digital service tax
The VAT law or Organic Law for Tax Simplicity and Progressiveness was Officially published on 31st December 2019. On 28 July 2020, the President approved the rules for administering the VAT measures on digital services. The new VAT comes into
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