Vietnam: Government issues Decree increasing cap on deductible interest expenses
On 24 June 2020, the Vietnamese Government has issued Decree No. 68/2020/ND-CP amending and supplementing Clause 3, Article 8 of Decree 20/2017/ND-CP (Decree 68). On 14 July 2020, the Vietnam Ministry of Finance (MOF) has also issued Official
See MoreAustria: Finance Ministry publishes a draft guide regarding the deferment of DAC6 reporting
On 20 July 2020, the Finance Ministry opened a public consultation on a draft guidance regarding the reporting requirement of cross border arrangements (DAC6). This guide covers the definition of terms, reportable arrangements, hallmarks and main
See MoreHong Kong: IRD extends the deadline for filing profits tax returns
On 14 July 2020, the Hong Kong Inland Revenue Department has published Circular Letter to Tax Representatives on an extension of the deadline for filing Profits Tax returns. Accordingly, the Inland Revenue Department decided to extend the due
See MoreSpain proposes postponement of reporting cross-border arrangements
The Spanish Government has proposed delayed reporting deadlines under the EU Directive 2018/822 related to mandatory disclosure and exchange of cross-border tax arrangements (DAC6). The proposal follows the adoption on 24 June 2020 by the EU
See MoreHong Kong: IRD publishes revised guidance concerning APA procedures
On 15 July 2020, the Inland Revenue Department (IRD) of Hong Kong released the DIPON 48 regarding advance pricing arrangement (APA) procedures. The Departmental Interpretation and Practice Notes No. 48 has been updated mainly to (a) reflect the
See MoreOECD: Report to the Meeting of G20 Finance Ministers
On 18 July 2020 the OECD published the tax report prepared for the virtual meeting of G20 Finance Ministers and Central Bank Governors hosted by Saudi Arabia. The OECD report notes that the tax agenda has been made even more relevant in the
See MoreFinland publishes guidance on hybrid mismatch rules
On 3 July 2020, the tax authorities have published guidance no. VH/2738/00.01.00/2020 concerning the legislation on cross-border hybrid mismatches, transposing the hybrid mismatch rules, the EU Anti-Tax Avoidance Directive (ATAD) 2016/1164 and
See MoreCroatia: Tax authority extends the DAC6 reporting timelines by six months
Due to coronavirus outbreak, the European Commission has recently agreed to delay the entry into force of certain European Union (EU) taxation measures. Among these is the delay of Council Directive 2018/822, commonly known as the Directive on
See MoreBelgium updates TP documentation guidance
On 30 June 2020, the tax authorities of Belgium published Circular Letter 2020/C/88 with updated Frequently Asked Questions (FAQs) concerning transfer pricing (TP) documentation requirements i.e. the local file (LF) and master file (MF) forms, the
See MoreDominican Republic: The DGII extends corporate tax return deadline
On 15 July 2020, the Directorate General of Internal Revenue (DGII) released a Notice 80-20 to announced that the submission deadline of corporate tax return and payment of tax for the tax year closed 31 March 2020 is extended until 31 August 2020.
See MoreBulgaria: National Revenue Agency extends deadlines for DAC6 reporting amid COVID-19
Due to coronavirus outbreak, the European Commission has recently agreed to delay the entry into force of certain European Union (EU) taxation measures. Among these is the delay of Council Directive 2018/822, commonly known as the Directive on
See MorePlatform for Collaboration on Tax Publishes Progress Report for 2020
On 10 July 2020 the Platform for Collaboration on Tax (PCT) published on its website the Progress Report 2020 outlining the tax cooperation between leading international organisations on supporting domestic resource mobilisation and combating the
See MoreBrazil: Bill proposes different COFINS tax regime in COVID-19 pandemic
Recently, the Senate proposed through the Complementary Bill 131/2020 different tax regime for the Contribution to the Financing of Social Security (COFINS) levied on the gross revenue earned by legal entities with high revenue using digital
See MoreIreland: Irish Revenue introduces new hybrid mismatch guide
On 8 July 2020, the Revenue published eBrief No. 137/20 on a new Tax and Duty Manual Part 35C-00-01, which provides an overview of the anti-hybrid rules that were introduced into Part 35C TCA 1997 by Finance Act 2019. This manual covers following
See MoreEU: Court Annuls decision of European Commission on Irish State Aid to Apple
A press release of 15 July 2020 stated that the General Court of the European Union has annulled the European Commission’s decision that tax rulings by Ireland in favour of Apple amounted to illegal state aid. The press release noted that the
See MoreBelgium extends tax return deadline to 29 October 2020
On 6 July 2020, Federal Public Service (SPF) Finance has issued a notice declaring that Biztax is available for the 2020 tax year. The notice indicates that the Minister of Finance granted an extension of the due date for filing the corporate
See MoreAustralia: Integrity rule law companion ruling finalized
In April 2019, Australian Taxation Office (ATO) released a draft Law Companion Ruling on the Organization for Economic Cooperation and Development (OECD) hybrid mismatch rules related to integrity rule. The ATO have now released draft LCR
See MorePhilippines: Tax authority issues a Resolution to guide of how to complete TP disclosure form
On 8 July 2020, the Tax authority issued Revenue Regulations No. 19-2020 dated July 8 2020, which provides guidelines of how to complete new transfer pricing (TP) disclosure form, Form BIR 1706. Also, this Resolution informs that taxpayers required
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