Australia: ATO finalized guidance on the arm’s length debt test
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 as one of the options for determining deductibility of interest and
See MoreItaly finalizes legislative decree for the implementation of DAC6
On 30 July, Italy has published Legislative Decree No. 100 in the Official Gazette as approved by the Council of Ministers for the implementation of the required reporting and exchange of information on cross-border arrangements as per
See MoreMalaysia ratifies BEPS multilateral convention (MLI)
On 4 August 2020, Malaysia published the Official Gazette PU (A) 224/2020 of 13 July 2020 providing ratification announcement of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), by way of the Double
See MoreFrance: Tax administration postpones deadline of annual transfer pricing return
On 14 August 2020, the tax administration announced that the deadline of annual transfer pricing return is extended until 31 January 2021 with financial year ended on 31 March 2020. Previously, On 10 June 2020, the tax authority announced to extend
See MoreCzech Republic: Financial Administration confirms delay of DAC6 reporting obligations
On 19 August 2020, the Financial Administration published an announcement about the Official publication of a Law 343/2020 of 14 August 2020 regarding the transposing the DAC6 cross-border arrangement reporting obligations. This Law will take enter
See MoreRussia: Tax audit guidelines on intra-group service expenses
The federal tax service of Russia has published guidance for lower tax authorities to follow in investigating the reasonableness of expenses claimed for intra-group services. The tax authorities did not have a unified approach to verifying
See MoreIndia: CBDT publishes guidance on mutual agreement procedure (MAP)
On 7 August 2020, the Central Board of Direct Taxes (CBDT) has published new Mutual Agreement Procedure (MAP) Guidance. The Guidance comprises of four sections, including: (A) introduction and basic information; (B) access and denial of
See MoreUS: North Carolina announces voluntary corporate transfer pricing resolution initiative
On 30 July 2020, the North Carolina Department of Revenue announced that it is implementing a voluntary initiative to expedite the resolution of corporate intercompany pricing issues. The purpose of this initiative is to fairly and consistently
See MoreMalaysia publishes updated guide on digital services tax
On 1 August 2020, the Royal Malaysian Customs Department issued an updated guide on digital services by foreign service providers. The Updated Guide replaced the earlier version dated 20 August 2019. Effective 1st January 2020, service tax
See MoreCzech Republic: Chamber of duties publishes a Law regarding dispute resolution
On 6 August 2020, the Chamber of duties Officially published Law 335/2020, which provides rules to ensure about the effective implementation of dispute resolution mechanisms under EU Council Directive 2017/1852. This Law will enter into force on 15
See MoreCosta Rica postpones VAT rules on cross-border digital services for two month
On 31 July 2020, Costa Rica published a directive that delayed the introduction of VAT rules on cross-border digital services by two months. Initially, the effective date was set for 1 August 2020. From October 1, 2020, VAT at 13% must be
See MoreLithuania defers MDR reporting deadlines for six months
On 30 July 2020, the Lithuanian State Tax Inspectorate released amendments to the Mandatory Disclosure Regime (MDR) rules to introduce a six-month postponement of the European Union (EU) Directive on Mandatory Disclosure and Exchange of
See MoreSouth Africa: National Treasury publishes draft 2020 Tax Law Amendment Bills
On 31 July 2020, the National Treasury published the 2020 Draft Taxation Laws Amendment Bill, which includes a proposed change to the definition of “affected transaction” for transfer pricing purposes. The proposed amended definition would be
See MoreColombia: DIAN starts a new system for the registration of commodity agreements
On 3 August 2020, the Colombian tax authority (DIAN) has launched an online system for registering commodities agreements for the purposes of carrying out commodity operations with related parties from abroad or in the Free Trade Zone or third
See MoreGreece: Parliament published two Laws to introduce various changes in transfer pricing context
On 31 July 2020 and on 29 July 2020, the Greek Parliament Officially published two Laws, L. 4714/2020 and L. 4712/2020 respectively regarding various sections of transfer pricing. The two Laws cover the following changes: Tax dispute Resolution
See MoreKenya publishes proposed digital service tax regulations for consultation
On 7 August 2020, the Kenya Revenue Authority has published the proposed Income Tax (Digital Service Tax) Regulations, 2020 for consultation. To ensure wide circulation and public participation as stipulated in the Constitution of Kenya
See MoreArgentina: AFIP announces additional suspension regarding inspections, assessments, appeals
On 8 August 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4786 of 3 August 2020, which provides an additional postponement in case of inspections, assessments, appeals, reimbursements, other methods related
See MoreFrance: Government publishes third amending Finance Law for 2020
On 31 July 2020, the Government Officially published Law No. 2020-935, which was basically third amending Finance (Budget) Law for 2020. The Law includes the following changes: Deferral of DAC6 reporting obligations According to the Law, the
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