Malta: CFR extends DAC6 notification deadline for non-disclosing intermediaries
On 18 September 2020, the Maltese Commissioner for Revenue (CFR) has notified that due to the deferral of the reporting deadlines as a result of the COVID-19 pandemic, the period allowed for notification by non-disclosing intermediaries is being
See MoreTransfer Pricing Brief: October 2020
AustraliaSpecial rules for hybrid instruments or entities: On 3 September 2020 amending legislation to clarifying the operation of the hybrid mismatch rules (amending legislation) received royal assent. The rules designed to prevent multinational
See MoreColombia: DIAN issues resolution on Mutual Agreement Procedure
On 21 August 2020, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales, DIAN) has issued Resolution No. 000085 in the official gazette which establishes Mutual Agreement Procedure (MAP) to avoid double taxation and
See MoreBosnia and Herzegovina deposits MLI ratification instrument
On 21 September 2020, Bosnia and Herzegovina 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. Based on the dates of
See MoreRussia: Federal Tax Service proposes to remove Turkey and Nigeria from the list of non-cooperative jurisdictions
The Russian Federal Tax Service proposes to remove Turkey and Nigeria from the list of non-cooperative jurisdictions that do not automatically exchange tax related information with Russia. The proposal was made for the purpose of updating the list
See MoreCzech Republic: BEPS multilateral instrument (MLI) enters into force
On 1 September 2020, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Czech Republic. Czech Republic deposited on 13 May 2020 its ratification
See MoreOman introduces CbC Reporting requirements
On 27 September 2020, Oman published Ministerial Decision No. 79/2020 in the Official Gazette announcing the introduction of Country-by-Country (CbC) reporting and notification requirements for multinational entity groups (MNE groups) headquartered
See MoreOman: Sultan amends Income Tax Law
On 14 September 2020, Mr. Haitham Bin Tarik, the Sultan of Oman issued Royal Decree No. 118/2020, which amended certain provisions of the Income Tax Law (ITL). The major changes are following: For tax years starting on or after 1 January 2020,
See MoreBrazil: Government submits a Bill to introduce a special tax arbitration process
On 3 September 2020, the Bill No. 4468/2020, was published in Senate to introduce a special tax arbitration procedure. The Bill proposed that during the time of tax audit, this special tax arbitration process would be available to deal with tax
See MorePhilippines: BIR issues a Circular to extend the deadline of Form BIR 1709
On 15 September 2020, the Bureau of Internal Revenue (BIR) published Revenue Memorandum Circular (RMC) No. 98-2020 to extend the submission deadline of related party transaction Form, or the Form BIR 1709. The initial extended due date is 30
See MoreTurkey 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
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