Ecuador: Government publishes Resolution regarding DST
On 22 August 2020, the Government published Resolution No. NAC-DGERCGC20-00000053 of 22 August 2020, which establishes rules for non-resident digital service providers regarding withholding VAT on digital services. According to this, non-resident
See MoreAustralia: ATO clarifying the operation of hybrid mismatch rules
Australia's hybrid mismatch rules have been updated with a number of technical amendments in order to clarify and improve the rules' operation. In the 2019–20 Budget on 2 April 2019, the Australian government announced the measure Tax
See MoreBelgium: Transfer pricing deadlines for FY 2019
The Belgian taxpayers should be aware of the transfer pricing documentation requirements and the applicable deadlines to comply with the requirements. The taxpayers have an obligation to prepare and file the following transfer pricing forms if
See MoreChile: SII publishes new transfer pricing reporting obligations
On 31 August 2020, the Internal Revenue Service (SII) published a Resolution No. 101, which establishes the obligations for companies to submit master file (Form 1950) and local file (Form 1951) respectively. The Resolution includes both Forms. The
See MoreSouth Korea: 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 South Korea. South Korea deposited its ratification instrument on 13 May
See MoreArgentina: AFIP releases new updated list of digital service providers
On 24 August 2020, the Federal Administration of Public Revenue (AFIP) published an updated list of digital service providers, who are subject to VAT withholding on supplies made to Argentine residents. The updated list effects from September
See MoreHong 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
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