South 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
See MoreBulgaria: Parliament publishes a Law to extend the deadline for DAC6
On 4 August 2020, the National Assembly Officially published a Law to extend the due date of cross border arrangements (DAC6). According to the Law, the deadline to report arrangements, which was implemented between 25 June 2018 and 30 June 2020,
See MoreHungary releases guideline on DAC6 reporting
On July 20, 2020, the Hungarian National Tax and Customs Administration published guidelines on the new reporting obligation for cross-border tax planning agreements (DAC6). The guidelines provide an overview of the reporting legislation, the
See MoreIndonesia: MLI enters into force
On 22 July 2020, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, MLI entered into
See MoreMalta issues legal notice regarding deferral of DAC6
On 31 July 2020, Malta’s Commissioner for Revenue has issued Legal Notice 315 of 2020, which enacts the deferral of reporting on EU cross-border arrangements (DAC6) due to COVID-19 pandemic. All reporting and data exchange deadlines in 2020, the
See MorePhilippines: Bureau of Internal Revenue issues a Circular regarding new RPT form
On 29 July 2020, the Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular No. 76-2020, which addresses the frequently asked questions regarding the submission of Related Party Transaction (BIR Form No. 1709, or RPT) Form, and its
See MoreSpain: Lower house of parliament approves draft bills for DST & FTT
On 30 July 2020, the Spanish Lower House of Parliament approved draft laws for a tax on digital services (DST) and a financial transaction tax (FTT). Accordingly, 3% tax to be levied on digital services including online advertising, online
See MoreTransfer Pricing Brief: August 2020
ArgentinaTransfer pricing information return: On 13 July 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4759/2020 of 8 July 2020, which make slight amendments in the transitional submission deadlines of the
See MoreCzech Republic: Supreme Court makes a decision regarding statute of limitations
On 2 July 2020, the Supreme Court issued a decision against the tax authorities regarding statute of limitations period extension. On 25 November 2015, the tax authority started a tax inspection concerning the taxpayer’s corporate income
See MoreHungary defers MDR reporting deadlines for six months
On 14 July 2020, the Hungarian Government issued a new regulation, deferring the reporting deadlines by six months. The deadline for the reporting of arrangements in the period between 25 June 2018 and 30 June 2020 will be 28 February
See MoreUS and Switzerland sign competent authority arrangement on implementation of arbitration
On 28 July 2020, U.S. and Switzerland signed an agreement for the implementation of the arbitration process provided for in Article 25 (Mutual Agreement Procedure) of the 1996 income tax treaty between the two countries as amended by the 2009
See More
Kenya deposits MLI ratification instrument
On 22 July 2020, Kenya 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. The MLI will enter into force for
See MoreSouth Africa: SARS publishes a notice regarding submission of 2020 income tax returns
On 3 July 2020, the South African Revenue Service (SARS) published Notice 741 in terms of section 25 for submission of 2020 income tax returns for both legal entities and natural person. This notice provides information about eligible legal entity
See More