Thailand reduces transfer pricing penalty amid Covid-19 pandemic
On 9 September 2020, the Revenue Department of Thailand announced to reduce fine for the late submission of the annual transfer pricing disclosure from THB 200,000 to THB 5,000 due to the Covid-19 pandemic, provided that the transfer pricing
See MoreIndonesia: Tax agency issues regulation on MAP process
On 11 August 2020, the Indonesian Directorate General of Taxation posted online Regulation No. PER-16/PJ/2020, on the mutual agreement procedure (MAP) rules under DTAs. The regulation covers: 1) the scope and definition of MAPs; 2) the deadline
See MoreSingapore publishes transfer pricing guidance in response to the Covid-19 outbreak
On 8 September 2020, the Inland Revenue Authority of Singapore updated its website by including guidance regarding transfer pricing in response to the Covid-19 pandemic. The guidance is provided in a following question and answering
See MoreAustralia: ATO clarifying the operation of hybrid mismatch rules
Australia's hybrid mismatch rules have been updated with a number of technical amendments in order to clarify and improve the rules' operation. In the 2019–20 Budget on 2 April 2019, the Australian government announced the measure Tax
See MoreSingapore: IRAS publishes e-Tax Guide for Variable Capital Companies
The Inland Revenue Authority of Singapore has issued an e-Tax guide about tax framework for Variable Capital Companies (VCC). The e-Tax Guide explains the tax framework for variable capital companies (VCCs). The VCC is a new corporate structure
See MoreSouth Korea: BEPS multilateral instrument (MLI) enters into force
On 1 September 2020, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for South Korea. South Korea deposited its ratification instrument on 13 May
See MoreHong Kong and Russia sign an agreement for the exchange of CbC report
On 3 September 2020, the Russian Federal Tax Service has announced that Hong Kong and Russia signed an agreement on the exchange of Country-by-Country (CbC) reports for the 2017 and 2018 reporting years. For reporting fiscal years beginning on or
See MoreIndonesia announces further tax relief measures due to COVID-19
On 22 August 2020, the Indonesian Directorate General of Taxation has published Regulation No.110/PMK.03/2020 regarding tax incentives for certain taxpayers in industrial sectors affected by the coronavirus pandemic. The regulations increased the
See MoreHong Kong and Serbia enter into tax pact
On 28 August, the Secretary for Financial Services and the Treasury, Mr Christopher Hui, on behalf of the Hong Kong Special Administrative Region Government, signed a comprehensive avoidance of double taxation agreement (CDTA) with Serbia. The
See MorePhilippines: Committee on Ways and Means submits a Bill regarding DST services
On 18 August 2020, the Committee on Ways and Means submitted a Bill, House Bill No. 7425 to the House of Representatives, which would serve as a substitute Bill of all the previous bills on the digital transactions tax. The Bill proposed to impose
See MoreTaiwan: NTBCA reminds profit-seeking enterprises to timely file tax returns
On 31 August 2020, Taiwan’s National Taxation Bureau of the Central Area (NTBCA) has issued a press release prescribing that profit-seeking enterprises should file annual income tax returns within the prescribed period to avoid delinquent
See MoreSouth 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 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 MoreThailand: Special tax relief measures for SME sector
The Thai Ministry of Finance has released the Royal Decree No. 707 and 708 regarding tax relief measures for SMEs in response to the Covid-19 pandemic, with effect from 13 July 2020. The Royal Decree No. 707 permits eligible SMEs that affected
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 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 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 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
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