Luxembourg: 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
See MoreTransfer Pricing Brief: May 2020
ArgentinaTransfer pricing information return: On 31 March 2020, the Government officially published General Resolution 4689/2020 of 30 March 2020, which provides a further extension of deadline for the transfer pricing return forms between 18 May
See MoreLatvia: Cabinet of Ministers approves the regulations to implement mandatory disclosure rules
On 17 April 2020, the Latvian Cabinet of Ministers approved the regulation “Rules on automatic exchange of information on reportable cross-border arrangements” to implement the European Union (EU) directive on mandatory disclosure and the
See MoreIreland: Revenue publishes guidelines on corresponding TP adjustments
On 24 April 2020, the Irish Revenue issued an eBrief No. 068/20 to announce about the publication of A new Tax and Duty Manual on corresponding transfer pricing (TP) adjustments. Guidelines for Article 9 Corresponding Adjustment claims This
See MoreMalta extends electronic filing extension of CIT returns amid COVID-19
On 29 April 2020, Malta’s Commissioner for Revenue has notified that the deadlines for the electronic filing of corporate income tax (CIT) returns for the have been extended as follows: Financial Year EndingManual Return DeadlineElectronic
See MoreFrance: FTA publishes additional guidance regarding DAC6
On 29 April 2020, the French Tax Authority (FTA) published additional guidelines concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). The guidelines describes the scope of the reporting obligations, including
See MorePortugal extends transfer pricing documentation deadline
On 24 April 2020, the government of Portugal published an order n.º 153/2020-XXII postponing the deadline to prepare and submit transfer pricing documentation to 31 August 2020 due to COVID-19
See MoreCOVID-19: Malaysia publishes third amendment providing further extension of deadline
On 28 April 2020, Malaysian Inland Revenue Board (IRB) has published third amendment to the return form filing programme for the year 2020 with further extending the deadlines for the filing of tax returns and making tax payments for companies,
See MoreChina extends monthly tax returns filing deadline amid COVID-19 pandemic
On 27 April 2020, the State Taxation Administration (STA) has announced the extension of deadline for filing monthly tax returns and tax payment for May 2020 from 15 May 2020 to 22 May 2020, due to the COVID-19
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