ArgentinaScope of transfer pricing rules: On 15 May 2020, the Argentine tax authorities (AFIP) officially published General Resolution 4717/2020 of 14 May 2020, which governs the control of transfer prices of international transactions. The new resolution replaces General Resolution No. 1122, and other complementary regulations.
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AustraliaFinancial transactions-General: On 25 May 2020, the Australian Taxation Office (ATO) issued Taxpayer Alert (TA) 2020/2, in relation to mischaracterised arrangements and schemes connected with direct foreign investment into Australian businesses.
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Special rules for hybrid instruments or entities: On 13 May 2020, the Treasury Laws Amendment Bill 2020 was presented in the House of Representatives that would make technical changes to the hybrid mismatch rules.
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BelgiumRestriction on interest deduction: On 5 May 2020, the tax authority of Belgium published Circular No. 2020/C/62 providing new clarifications on interest deduction limitation rule. Accordingly, loans made before 17 June 2016 are excluded from the scope of “excess borrowing costs” whose deductibility is limited for corporate income tax purposes.
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BrazilDigital economy transactions-General: On 4 May 2020, Brazil proposed a Bill no. 2358/2020 to introduce the digital service tax (DST). The Bill proposes the digital service tax rate from 1% to 5% on the basis of amount of gross revenue from taxable supplies.
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CyprusCompliance with BEPS standards: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Cyprus on 1 May 2020.
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Czech RepublicCompliance with BEPS standards: Czech Republic deposited on 13 May 2020 its BEPS MLI ratification instrument. The MLI will generally enter into force for the Czech Republic on 1 September 2020.
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DenmarkRequirements-Scope of transfer pricing rules: 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.
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EcuadorTransfer pricing information return: On 6 May 2020, the Internal Revenue Service (SRI) published Resolution NAC-DGERCGC20-00000032, which extends the deadline of Annex on Related Party Operations and the Comprehensive Transfer Pricing Report.
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FinlandRequirements-Scope of transfer pricing rules: On 8 May 2020, the EU Commission has proposed a number of amendments to the DAC6 Directive governing reportable cross-border arrangements. On the basis of the proposal, the Finnish tax authority published a guideline which is adjusted the deadlines and the layout of the reporting schedule.
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FranceRestriction on interest deduction: On 13 May 2020, the tax authority published final guidelines regarding restrictions on interest deduction. Accordingly, the additional borrowing costs are deductible for the tax period during which they were incurred, but only up to 30% of the EBITDA and EUR 3 million safe harbor.
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IcelandRestriction on interest deduction: On 6 May 2020, the Icelandic Parliament passed a Bill No.1329 amending safe harbor threshold for Iceland’s interest deduction restriction (30% of EBITDA).
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IndiaMAP: On 6 May 2020, the Indian Central Board of Direct Taxes issued Notification No. 23/2020, amending the 2020 income tax rules on mutual agreement procedures (MAPs) regarding dispute resolution.
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IndonesiaCompliance with BEPS standards: Indonesia deposited on 28 April 2020 its BEPS MLI ratification instrument. The MLI will generally enter into force for Indonesia on 1 August 2020.
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IrelandCorresponding adjustment: On 24 April 2020, the Irish Revenue issued an eBrief No. 068/20 concerning the publication of a new Tax and Duty Manual which sets out the guidelines for corresponding transfer pricing (TP) adjustments.
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KenyaDigital economy transactions-General: On 5 May 2020, the Kenya government published the Finance Bill, 2020 that includes a proposal for digital services tax and minimum tax. The bill proposes that income from services earned through a digital marketplace in Kenya will be taxed at the rate of 1.5% on the gross transactional value.
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LatviaRequirements-Scope of transfer pricing 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 EU directive on mandatory disclosure and the exchange of cross-border tax arrangements.
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LuxembourgRequirements-Scope of transfer pricing rules: On 14 May 2020, the Luxembourg Tax Administration has issued guidelines concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6).
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RussiaAPAs-General rules: In March 2020, the Russian Ministry of Finance (MoF) released an amended version of a draft law to improve tax control over prices and procedure for entering into advanced pricing agreements (APA). The draft measures are expected to be adopted in 2020 and effects from 1 January 2021.
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Saudi ArabiaCompliance with BEPS standards: On 1 May 2020, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force with respect to Saudi Arabia.
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SwedenFinancial transactions-General: On 24 April 2020, the Swedish tax agency has issued a guidance considering the OECD principles regarding transfer pricing for financial transactions.
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USMAP & APA: On 11 May 2020, IRS officials announced certain modifications to procedures for filing documents under Rev. Proc. 2015-40, 2015-35 IRB 236 (mutual agreement procedure (MAP) requests), and Rev. Proc. 2015-41, 2015-35 IRB 263 (advance pricing agreement (APA) requests and APA annual reports).
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