Turkey intends increase in CIT rate for the tax year 2021 and 2022
On 2 April 2021, the Turkish Government submitted a Draft Law to the Turkish Parliament. Through the Draft Law, Turkey intends to increase the corporate income tax (CIT) rate for the tax years 2021 and 2022. The proposed tax rate is 25% for 2021
See MoreGermany: BEPS MLI enters into force
On 16 March 2021, 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, MLI entered into
See MoreIndonesia: DGT updates XML schema for CbC reporting
On 4 March 2021, the Indonesian Directorate General of Taxation (DGT) updated the XML schema (version 2.0) for country-by-country reports (CbCR). The update includes the new XSD schema; a procedure for creating XML files; and technical guidance
See MoreCyprus gazettes the law to implement mandatory disclosure rules
On 31 March 2021, the Cyprus official gazette published the law (Ν. 41(Ι)/2021, the Law) amending the Law on Administrative Cooperation in the field of Taxation (Law N. 205(I)/2012). The Law transposed the EU Council Directive 2011/16 referred to
See MoreTransfer Pricing Brief: April 2021
ChileCompliance with BEPS standards: On 1 March 2021, 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
See MoreExtension of tax compliance due dates amid COVID-19 pandemic
CountryCompliance IssueDue dateExtended Related NewsAustriaCIT payment31-Mar-2130-Jun-21See MoreBelgiumCIT Return30-Jun-2128-Oct-21See MoreBulgariaCIT Return31-Mar-2130-Jun-21See MoreCroatiaCIT Return30-Apr-2130-Jun-21See MoreJapanCIT
See MoreOECD: Request for input on proposed changes to commentary on Article 9 of OECD Model
On 29 March 2021 the OECD issued a public discussion draft on proposed changes to the commentary to Article 9 (associated enterprises) of the OECD Model Tax Convention. The amendments are to be included in the next update of the OECD
See MoreGreece deposits BEPS MLI ratification instrument
On 30 March 2021, the OECD announced that Greece has deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI will enter into force for
See MoreIreland: Revenue publishes an eBrief to update guidance on anti-hybrid rules
On 29 March 2021, the Irish Revenue published an eBrief No. 068/21 to announce a manual to update the guidance on anti-hybrid rules. On the similar day, the Revenue also published a Tax and Duty Manual, which provides guidance on the anti-hybrid
See MoreUS: IRS releases announcement and report concerning APMAs program
On 23 March 2021, the US IRS released an advance version of Announcement 2021-6 regarding the Advance Pricing and Mutual Agreement (APMA) program’s annual report on advance pricing agreements (APAs) for 2020. This twenty-second report
See MoreCosta Rica: Ministry of Finance issues resolution on APA procedures
On 24 March 2021, the Costa Rican Ministry of Finance released a Resolution No. DGT-R-14-2021, providing new guidelines on advance pricing agreements (APAs). The resolution provides the details guidelines of APAs procedures including definitions
See MoreOECD: Profiles for Countries Applying Arbitration under the MLI
On 23 March 2021 the OECD published Arbitration Profiles for 30 jurisdictions that are applying the arbitration provisions in Part VI of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit
See MoreMorocco declares maximum interest rate 1.63% on shareholder loans
On 18 March 2021, Morocco has published Ministerial Decree 423.21 in the Official Gazette regarding the reduction of maximum interest rate for loans granted by direct shareholders from 2.23% to 1.63% for FY 2021. Interest expense on loans will
See MoreUK adopts CbC reporting XML schema 2.0
The UK tax authority has updated the country-by-country (CbC) reporting schema to XML 2.0 for submissions to HM Revenue & Customs (HMRC). All CbC reports must use the new 2.0 XML format and submitted to HMRC on or after 1 January 2021. The
See MoreQatar: GTA extends tax filing deadlines for 2020
On 24 March 2021, the General Tax Authority (GTA) of Qatar published Circulars No. 1 and 2 of 2021 to extend the deadline for filing tax returns for the 2020 tax year in response to the Covid-19 pandemic. According to Circular 1 of 2021, the new
See MoreSweden: Parliament accepts Bill to implement EU ATAD reverse hybrid mismatches
On 16 March 2021, the Swedish Parliament (Riksdag) has accepted Bill No. 2020/21:111 to implement EU Anti-Tax Avoidance Directive (ATAD) reverse hybrid mismatches. In this bill, it is proposed that rules be introduced regarding the tax treatment
See MorePeru announces the most appropriate method in the case of intra-group services
On 18 March 2021, the Peruvian tax authorities (SUNAT) has issued Report No. 135-2020-SUNAT/7T0000, through which SUNAT announced the use of the most appropriate method to determine the market value of services other than those classified as low
See MoreEcuador: National Tax Authority amends rules on submission request for APAs
On 11 March 2021, the Deputy General Director of the Internal Revenue Service (SRI) Officially issued and signed Resolution No. NAC-DGERCGC21-0000001 in Spanish, which provides several changes to the transfer pricing regime on advance pricing
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