Argentina: Government publishes General Resolution regarding TP returns deadline delay
On 29 February 2020, Government published General Resolution 4680/2020 of 28 February 2020 regarding the delayed due dates of submitting transfer pricing (TP) return in the Official Gazette. The filing deadline for the TP return forms (i.e. Form F.
See MoreSouth Africa: Finance Minister delivers draft Budget for 2020-2021
On 26 February 2020, the Finance Minister, Tito Mboweni, delivered National Budget for the year 2020-2021. Some provisions of budget 2020-2021 include: Corporate income tax The standard corporate income tax rate was proposed to remain
See MoreNigeria: Tax Appeal Tribunal makes a decision on a transfer pricing case
On 19 February 2020, the Tax Appeal Tribunal made a decision regarding a transfer pricing case, entitled “Prime Plastichem Nigeria Limited v Federal Inland Revenue Service (FIRS), in favour of the FIRS on all the issues raised for determination
See MoreSpain: Cabinet approves a draft bill for digital services tax (DST)
On 18 February 2020, the Spanish Cabinet reportedly approved a draft bill for the introduction of a digital services tax (DST). A 3% DST will be applicable for large companies whose respective groups have revenue of at least EUR 750 million
See MoreLatvia implements EU ATAD hybrid mismatch measures
On 11 February 2020, Latvia published the Law of 30 January 2020 on Amendments to the Corporate Income Tax Act in the official gazette. The law includes the provision for the implementation of the hybrid mismatch measures of the EU Anti-Tax
See MoreEstonia implements EU ATAD 2 from 1 January 2020
Estonia has implemented the EU Anti-Tax Avoidance Directive (2017/952) (ATAD 2). ATAD 2 amends the EU Directive 2016/1164 which extends the scope of the Hybrid Mismatches Rules to a wider range of transactions and also to apply to transactions with
See MoreTurkey: Revenue Administration issues decree on transfer pricing documentation
On 25 February 2020, the Turkish Revenue Administration has published Presidential Decree No. 2151 in the official gazette, which amends transfer pricing documentation rules. The decree aims to set out OECD’s Base Erosion and Profit Shifting
See MoreMalaysia gazettes Labuan Business Activity Tax (Amendment) Act 2020
On 10 February 2020, Malaysia has gazetted the Labuan Business Activity Tax (Amendment) Act 2020 (“the Amendment Act”) which comes into operation on 11 February 2020. The following tax measures are included in the act. A company in Labuan
See MoreAustria: Finance Ministry publishes updated information regarding DST
On 24 February 2020, the Ministry of Finance published updated information regarding the process of how to register and make payment of digital service tax
See MoreOECD: Stage 1 peer review reports on dispute resolution
On 24 February 2020 the OECD published the eighth round of stage 1 peer review reports. The reports related to for Brunei Darussalam, Curaçao, Guernsey, Isle of Man, Jersey, Monaco, San Marino and Serbia. The reports look at the extent to which
See MoreBrazil: Federal Revenue encourages taxpayers to make comments on CbC reporting
On 13 February 2020, the Department of Federal Revenue encouraged the taxpayers or multinational enterprises to give comments regarding country-by-country (CbC) reports for public consultation documents arranged by the OECD up to 6 March 2020. This
See MoreMalta amends EU ATAD Implementation Regulations
Recently, Malta has published Legal Notice No. 29 of 2020 in the Official Gazette amending Regulation 10 of the EU Anti-Tax Avoidance Directives (ATAD) Implementation Regulations. The Regulation states that the reverse hybrid rules will apply from
See MorePoland: Council of Ministers submit ATAD2 hybrid mismatch measures to parliament
On 5 February 2020, Poland's Council of Ministers submitted some tax measures in parliament including the hybrid mismatch measures of the EU Anti-Tax Avoidance Directive as amended (ATAD2). ATAD2 would address tax avoidance through hybrid
See MorePoland: Administrative Court allows expenditure on intra-group services
On 6 February 2020, Polish Administrative Court (the “Court”) issued its decision on a transfer pricing case regarding Poland vs Shared Service Center. A shared service center (SSC) in Poland both provided intra-group services to the group
See MoreLuxembourg amends draft law implementing DAC6
On 14 February 2020, Luxembourg published a revised version of the draft law 7465 amending the original provisions on the professional privilege exemption. Luxembourg Government submitted the draft law on 8 August 2019 which has not been passed
See MoreQatar introduces directives on MAP
On 11 February 2020, Qatar's General Tax Authority (GTA) has published following six directives on the application of the mutual agreement procedure (MAP) under double taxation avoidance agreements in relation to the implementation of base erosion
See MoreAustralia introduces a bill to expand definition of SGE
On 12 February 2020, the Treasury Laws Amendment (2020 Measures No. 1) Bill 2020 was submitted in the Australian House of Representatives. This bill contains two measures that maintain the integrity and efficiency of Australia's tax
See MoreAustralia: ATO issues urgent notification for CbCR lodgments
The Australian Taxation Office (ATO) has issued an email notification regarding an essential update on Country-by-Country reporting (CbCR) lodgments. An increased number of data validations will now be performed on lodgments before they are
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