South 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
See MoreEgypt: Parliament approves BEPS multilateral instrument (MLI)
On 18 August 2020, the Egyptian House of Representatives (Parliament of Egypt) has approved several presidential decrees on international agreements. Among the agreements, the Parliament has approved the Multilateral Convention to Implement Tax
See MoreNew Zealand: Inland Revenue releases guidance on transfer pricing amid COVID-19
Recently, New Zealand’s Inland (IR) Revenue has released guidance regarding practice issues for transfer pricing due to the COVID-19 pandemic. The COVID-19 pandemic has created an impact on specific sectors and businesses substantially. The
See MorePakistan: FBR approves the Audit Policy 2019
On 26 August 2020, the Pakistan Federal Board of Revenue (FBR) announced the approval of the Audit Policy 2019. The Audit Policy 2019 shall apply to persons or classes of persons falling under all or any of the three domestic Federal Tax Statutes
See MoreBrazil: Chamber of Deputies considers new draft Bill regarding digital service tax
On 19 August 2020, a Bill 218/2020, the social contribution on digital services (CSSD), was submitted and considered by the Chamber of Deputies, which provides the introduction of digital service tax (DST). Previously, On 4 May 2020, Mr. João
See MoreTaiwan: MOF announces draft amendments to transfer pricing guidelines
On 18 August 2020, Taiwan’s Ministry of Finance (MOF) has announced draft amendments to certain transfer pricing provisions based on chapter 6 of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The
See MoreEcuador: Reminder for the effective date of Vat law regarding digital service tax
The VAT law or Organic Law for Tax Simplicity and Progressiveness was Officially published on 31st December 2019. On 28 July 2020, the President approved the rules for administering the VAT measures on digital services. The new VAT comes into
See MoreAustralia: 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
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