| Argentina | Transfer pricing information return: On 13 July 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4759/2020 of 8 July 2020, which make slight amendments in the transitional submission deadlines of the new Form F. 2668. Under the new Resolution, the exact dates are changed to between the 3 and 7 of October from between the 10 and 14 of October 2020, depending on the last digit of the tax ID number. See the story in Regfollower |
| Austria | Scope of transfer pricing rules: On 20 July 2020, the Finance Ministry opened a public consultation on a draft guidance regarding the reporting requirement of cross border arrangements (DAC6). The guideline deferred the deadline for the electronic submission of the first DAC6 reports through FinanzOnline up to 31 October 2020, without charging any penalty. See the story in Regfollower |
| Belgium | Digital economy transactions-General: In July 2020, Belgium again reintroduced digital services tax (DST) that was first proposed in January 2019, but it was on hold due to the general elections. As proposed, a digital services tax (DST) would impose a 3% tax rate on enterprises that generate revenue from digital services. See the story in Regfollower CbC reporting requirement/Local File/ Master File: On 30 June 2020, the tax authorities of Belgium published Circular Letter 2020/C/88 with updated Frequently Asked Questions (FAQs) concerning transfer pricing (TP) documentation requirements i.e. the local file (LF) and master file (MF) forms, the country-by-country (CbC) report, and the CbC notification form. See the story in Regfollower |
| Bulgaria | Scope of transfer pricing rules: Recently, the Nation Revenue Agency announced that it will be providing the six-month deferral for the initial reporting deadlines for cross-border arrangements (DAC6). The exact deadlines are not certain yet. See the story in Regfollower |
| Canada | Transfer pricing case-ALP application: On 26 June 2020, the Federal Court of Appeal made decision in a transfer pricing case, entitled “The Queen v. Cameco Corporation, 2020 FCA 112” in favour of the taxpayer, i.e. Cameco Corporation. The Canadian Revenue Agency found that the transactions between Cameco Corp and the Swiss subsidiary (CEL) constituted a sham arrangement resulting in improper profit shifting. Cameco Corp. disagreed with the Agency and brought the case to the Canadian Tax Court. See the story in Regfollower |
| Chile | Compliance with BEPS standards: On 9 July 2020, the Senate approved the ratification of multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). See the story in Regfollower |
| Croatia | Scope of transfer pricing rules: Recently, the Tax Authority has opted to postpone the DAC6 reporting deadlines. The deadline to report arrangements, which was implemented between 25 June 2018 and 30 June 2020, is deferred from 31 August 2020 to 28 February 2021. See the story in Regfollower |
| Cyprus | Scope of transfer pricing rules: The submission of DAC6 information in Cyprus is extended as information on reportable arrangements carried out between 25 June 2018 and 30 June 2020 is due by 28 February 2021 and arrangements carried out between 1 July 2020 and 31 December 2020 is due within 30 days starting from 1 January 2021. See the story in Regfollower |
| Denmark | Scope of transfer pricing rules: On 29 June 2020, the Tax authority updated guidance to announce that the primary deadline of reporting cross-border arrangements (DAC6) are extended by six-months. See the story in Regfollower |
| Dominican Republic | Filing deadlines: On 15 July 2020, the Directorate General of Internal Revenue (DGII) released a Notice 80-20 to announce that the submission deadline of corporate tax return and payment of tax for the tax year closed 31 March 2020 is extended until 31 August 2020. See the story in Regfollower |
| Ecuador | Comparability-PLI used: On 1 July 2020, the Government published Resolution No. NAC-DGERCGC20-00000046 of 1 July 2020, which amends the calculation of profit level indicators. See the story in Regfollower |
| Egypt | Compliance with BEPS standards: On 15 July 2020, the Egyptian Cabinet has approved a draft law for the ratification of the multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). See the story in Regfollower |
| Estonia | Scope of transfer pricing rules: On 26 June 2020, the Estonian Ministry of Finance has proposed for the deferral of six months reporting on EU cross-border arrangements (DAC6) due to COVID-19 pandemic. See the story in Regfollower |
| Finland | Special rules for hybrid instruments or entities: On 3 July 2020, the tax authorities have published guidance no. VH/2738/00.01.00/2020 concerning the legislation on cross-border hybrid mismatches, transposing the hybrid mismatch rules, the EU Anti-Tax Avoidance Directive (ATAD) 2016/1164. See the story in Regfollower |
| France | Scope of transfer pricing rules: On 19 July 2020, the Parliament approved the six-month extension of reporting on cross-border arrangements (DAC6), which was provided by Council Directive (EU) 2020/876. The deadline to report arrangements, which was implemented between 25 June 2018 and 30 June 2020, is deferred until 28 February 2021. See the story in Regfollower |
| Germany | Scope of transfer pricing rules: On 6 July 2020, an announcement from federal Ministry of Finance declares that, the German government will not adopt the option to allow up to a 6-month deferral of the reporting deadlines under EU Directive 2018/822 reporting cross-border arrangements (DAC6). See the story in Regfollower |
| Greece | Scope of transfer pricing rules: On 7 July 2020, the Government opened a public consultation on a draft guidance providing a six-month deferral to the reporting deadlines under DAC6 following the adoption on 24 June 2020 by the Council of the EU of amendments to the Directive. See the story in Regfollower Special rules for hybrid instruments or entities: On 7 July 2020, the Ministry of Finance published a draft bill related to the transposition of anti-hybrid rules for public consultation. The anti-hybrid rules would apply as per 1 January 2020. But, in the banking sector, this would be applicable from 1 January 2023. See the story in Regfollower |
| Hong Kong | APAs-General rules: On 15 July 2020, the Inland Revenue Department (IRD) of Hong Kong released the DIPON 48 regarding advance pricing arrangement (APA) procedures. See the story in Regfollower |
| Ireland | Special rules for hybrid instruments or entities: On 8 July 2020, the Revenue published eBrief No. 137/20 on a new Tax and Duty Manual Part 35C-00-01, which provides an overview of the anti-hybrid rules that were introduced into Part 35C TCA 1997 by Finance Act 2019. See the story in Regfollower |
| Kazakhstan | Digital economy transactions-General: On 30 June 2020, the lower house of Parliament approved a Bill regarding digital service taxation (DST) and electronic sales of goods. According to the Bill, foreign companies that apply their digital platforms for electronic sales of goods or services in Kazakhstan are considered as payers of value added tax (VAT). See the story in Regfollower |
| Latvia | Scope of transfer pricing rules: On 29 June 2020, Latvian Ministry of Finance has announced that the first reporting deadlines of cross-border arrangements (DAC6) provided by Council Directive (EU) 2020/876 will be deferred by six months in order to provide taxpayers and intermediaries dealing with the impacts of COVID-19. See the story in Regfollower |
| Luxembourg | Scope of transfer pricing rules: On 22 July 2020, the Luxembourg Parliament approved Bill No. 7625 which providing an extension for filing and exchanging information on reportable cross-border arrangements under Directive 2018/822/EU (DAC 6) from 31 August 2020 to 28 February 2021. See the story in Regfollower |
| Malta | Scope of transfer pricing rules: On 2 July 2020, the Maltese Commissioner for Revenue has announced the deferral of reporting on EU cross-border arrangements (DAC6) due to COVID-19 pandemic. All reporting and data exchange deadlines in 2020, the first reporting year, are thus postponed by 6 months. See the story in Regfollower |
| Oman | Information exchange-Multilateral: On 16 July 2020, Oman signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA). See the story in Regfollower Compliance with BEPS standards: On 7 July 2020, Oman deposited its instrument of ratification for the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI). See the story in Regfollower |
| Philippines | Transfer pricing information return: On 8 July 2020, the Tax authority issued Revenue Regulations No. 19-2020 dated July 8 2020, which provides guidelines of how to complete new transfer pricing (TP) disclosure form, Form BIR 1706. See the story in Regfollower |
| Romania | Scope of transfer pricing rules: On 1 July 2020, Romania has published Ordinance No. 107 in the Official Gazette regarding deferral of reporting on EU cross-border arrangements (DAC6) due to Covid-19 pandemic. See the story in Regfollower |
| Spain | Scope of transfer pricing rules: The Spanish Government has proposed delayed up to six months reporting deadlines under the EU Directive 2018/822 related to mandatory disclosure and exchange of cross-border tax arrangements (DAC6). See the story in Regfollower |
| Tanzania | Scope of transfer pricing rules: On 1 July 2020, the Tanzania Revenue Tax Authority issued the Transfer Pricing Guidelines 2020, which provides instructions on how to apply Transfer Pricing Regulations, 2018. See the story in Regfollower |
| US | Restriction on interest deduction: On 28 July 2020, the Internal Revenue Service issued final regulations regarding the deduction limits for business interest expense, including basic statutory amendments made by the CARES Act. For tax years beginning after December 31, 2017, business interest expense deductions are generally limited to the sum of 30 percent (or 50 percent, as applicable) of the taxpayer’s adjusted taxable income. See the story in Regfollower |
| Vietnam | Restriction on interest deduction: On 24 June 2020, the Vietnamese Government has issued Decree No. 68/2020/ND-CP that increased cap on deductible interest expenses from 20% of earnings before interest, tax, depreciation and amortization (EBITDA) to 30% of EBITDA. See the story in Regfollower |
Transfer Pricing Brief: August 2020
06 August, 2020
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