India: CBDT amends rules for resolution of tax disputes under MAP
On 6 May 2020, the Indian Central Board of Direct Taxes issued Notification No. 23/2020, amending the 2020 income tax rules on mutual agreement procedures (MAPs) regarding dispute resolution. Under the revised rules, the authorities can now try
See MoreUS: IRS announces to change the procedures for filing MAP and APA
On 11 May 2020, IRS officials announced certain modifications to procedures for filing documents under Rev. Proc. 2015-40, 2015-35 IRB 236 (mutual agreement procedure (MAP) requests), and Rev. Proc. 2015-41, 2015-35 IRB 263 (advance pricing
See MoreKenya publishes finance bill 2020 including taxation of digital economy
On 5 May 2020, the Kenya government published the Finance Bill, 2020 that includes a proposal for digital services tax and minimum tax. The bill proposes that income from services earned through a digital marketplace in Kenya will be taxed at the
See MoreEcuador: SRI publishes a Resolution to extend the TP report filing deadline
On 6 May 2020, the Internal Revenue Service (SRI) published Resolution NAC-DGERCGC20-00000032 , which extends the deadline of Annex on Related Party Operations and the Comprehensive Transfer Pricing Report for fiscal year 2019 between 10 and 28
See MoreAustralia: New proposals on Hybrid mismatch rule
On 13 May 2020, the Treasury Laws Amendment Bill 2020 was presented in the House of Representatives that would make technical changes to the hybrid mismatch rules addressing integrity of income tax laws and their application to multinational
See MoreArgentina: AFIP publishes Resolution regarding new transfer pricing rules
On 15 May 2020, the Argentine tax authorities (AFIP) Officially published General Resolution 4717/2020 of 14 May 2020, which governs the control of transfer prices of international transactions. The new resolution replaces General Resolution No.
See MoreRussia: Draft law to revise APA procedures
In March 2020, the Russian Ministry of Finance (MoF) released an amended version of a draft law to improve tax control over prices and procedure for entering into advanced pricing agreements (APA). The draft measures are expected to be adopted in
See MoreIceland: Parliament passes a bill to amend various taxes
On 6 May 2020, the Icelandic Parliament passed a Bill No.1329 amending income, withholding, excise, and VAT laws. The bill includes the amendments for corporate taxpayers in relation to the ISK 100 million safe harbor threshold for Iceland's
See MoreLuxembourg: Tax Administration issues guidance on DAC6
On 14 May 2020, the Luxembourg Tax Administration has issued guidelines concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) as per Council Directive (EU) 2018/822 of 25 May 2018. The guidelines describe Object,
See MoreFrance: Tax authority publishes final guidelines for ATAD interest deduction limitations
On 13 May 2020, the tax authority published final guidelines regarding restrictions on interest deduction, including the amendments introduced by the Finance Law for 2019 to implement the EU Anti-Tax Avoidance Directive (ATAD). In accordance with
See MoreBelgium clarifies interest restriction rule due to COVID-19 pandemic
On 5 May 2020, the tax authority of Belgium published Circular No. 2020/C/62 providing new clarifications on the “grandfathering” rule, under the interest deduction limitation rule, loans made before 17 June 2016 are excluded from the scope of
See MoreCzech Republic deposits ratification instrument for MLI
On 13 May 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, Czech Republic
See MoreBrazil: A draft Bill published to introduce digital service tax
On 4 May 2020, Mr. João Maia, a Brazilian politician and Brazilian Congressman, proposed a Bill no. 2358/2020 to introduce the digital service tax (DST) and was submitted it in the Chamber of Deputies. The proposed tax, known as the contribution
See MoreUS: Tax court ruled in favor of the IRS for Whirlpool vs Commissioner case
On 5 May 2020, the US tax court made a decision in favor of the IRS a case involving the Whirlpool Financial Corp. and related foreign affiliate corporations. The Court upheld the Internal Revenue Service's (IRS) application of the Subpart F
See MoreSweden: Tax agency implements the OECD principles on financial transactions
On 24 April 2020, the Swedish tax agency has updated the financial transaction page. In February 2020, the OECD published a new Chapter X of the guidelines on financial transactions. Financial transactions between companies within a group are
See MoreOECD: Tax Talk Summarises Ongoing Tax Projects
A Tax Talk held by the OECD on 4 May 2020 summarised the position on the current tax work in connection with the Covid-19 crisis and on the base erosion and profit shifting (BEPS) project. Tax measures in the Covid-19 crisis The Forum on Tax
See MorePeru: SUNAT further modifies tax filing deadline amid COVID-19 pandemic
On 29 April 2020, the Peruvian tax authorities (SUNAT) issued Resolution No. 075-2020/SUNAT in the Official Gazette modifying previous Resolution No. 055-2020/SUNAT and 065-2020/SUNAT in response to COVID-19 pandemic. The Resolution further
See MoreDenmark: Tax authority publishes a guide regarding DAC6
On 17 April 2020, the tax authority published a guide regarding the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) and will enter into force as from 1 July 2020. The guidelines describe the scope of the reporting
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