AustraliaTreatment of losses-carry back: The Australian Taxation Office (ATO) published guidance on the loss carry back offset relief introduced as part of measures for the 2020-21 Budget. Loss carry back provides a refundable tax offset that eligible corporate entities can claim: (i) after the end of their 2020–21 and 2021–22 income years (ii) in their 2020–21 and 2021–22 company tax returns.
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Austria
Payment procedure: On 17 December 2020, the Parliament approved winter package due to COVID-19 pandemic. Under the package, the existing tax payments are to be extended from 15 January 2021 to 31 March 2021. Also, during the period, no interest charges on deferred payments or late payment fines are imposed.
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BrazilIncentives-other: On 18 November 2020, the Revenue published an Ordinance No. 30 of 18 November 2020, setting the revenue limits for the purpose of paying state tax on the sale of goods, interstate and inter-municipal transportation and communication services and the municipal service Tax under the simplified tax regime in 2021.
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Costa RicaMain corporate tax rate: On 8 December 2020, the Costa Rican Ministry of Finance has published the Executive Decree that provides for new corporate tax brackets for 2021. Decree No. 42733-H comes into force on 1 January 2021 and replaces the previous decree on tax rates published in September 2019.
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Compensation for overpaid tax and refunds: On 18 December 2020, Costa Rica’s Ministry of Finance has published a Resolution  providing reduced the interest rate for late tax payments and refunds of overpayments to 10.31% (from 10.54%). The rate is based on the average commercial lending rate of Costa Rica’s national banks and is effective from 1 January 2021.
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CroatiaReduced rates: On 11 December 2020, the Government published Tax Reform Law for the year 2021.The law provides for a reduction in the corporate tax rate for SMEs from 12% to 10%, which applies to SMEs with an annual turnover of up to HRK 7.5 million.
Withholding tax rate: The law also provides for a reduction in the withholding tax rate for dividends and profit shares from 12% to 10%.
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EgyptTaxation of capital gains: On 16 December 2020, the Egyptian Ministry of Finance published a decree setting out the tax treatment of capital gains from the sale or disposal of unlisted shares by non-residents. The decree also published the relevant reporting and payment form for capital gains tax.
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FinlandCentral management and control: On 16 December 2020, the Finnish Tax Authority published an overview of the tax changes for 2021. Accordingly, with effect from 1 January 2021, a Finnish company is resident in Finland if it is registered or established in Finland. In addition, foreign companies whose effective place of administration is in Finland are also deemed to be resident in Finland for tax purposes.
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France Main corporate tax rate: On 30 December 2020, the Government Officially published Finance Law for the year 2021. Accordingly, the standard corporate income tax rate for the 2021 financial year is 26.5% (sales of less than EUR 250 million) and 27.5% for large companies (sales of EUR 250 million or more).
Reduced rates: The reduced corporate income tax rate of 15% up to EUR 38,120 profit is extended to companies with an annual turnover not exceeding EUR 10 million (the previous threshold was EUR 7.63 million);
Incentives for small business: A new tax credit for SMEs is introduced for expenses incurred between 1 October 2020 and 31 December 2021 for energy renovations of buildings or parts of buildings, which is equal to 30% of the costs.
Incentives for industry/manufacturing: The new law provides for a 30% R&D tax credit on qualifying research expenses up to €100M and a 5% credit above this limit if certain criteria are met.
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IndonesiaDividends: On 2 November 2020, the Indonesian President has signed the Law on Job Creation (Law No. 11 of 2020). The law provides tax exemptions on dividends.
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JapanTreatment of losses-carry forward: In order to offset the negative impact of the COVID-19 pandemic, the government is planning to include loss carry forward relief. Under the loss carry forward relief plans, entities will be allowed to carry forward net operating losses and offset up to 100% of taxable income for up to five years rather than the usual 50% offset limit. Where outstanding losses remain, the standard 50% offset limit would apply for the following five years.
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NorwayWithholding tax rate: On 19 December 2020, the Norwegian parliament passed the national budget for 2021. The budget includes a proposal of 15% withholding tax on interest, royalties, and rent payments for certain physical assets paid by companies operating in Norway to related companies in low-tax countries.
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Pakistan Incentives: On 2 December 2020, the Ministry of Law and Justice of Pakistan has issued a copy of the Special Technology Zones Authority Ordinance 2020.  Accordingly, the government has granted a comprehensive duty and tax incentives for a period of 10 years to investors operating in the proposed special technology zones (STZs).
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Philippines Main corporate tax rate: On 27 November 2020, the Senate has passed the Corporate Recovery and Tax Incentives for Enterprises Act (herein referred to as “CREATE”). The CREATE bill seeks to lower corporate income tax rates from 30% to 25%, which will apply retroactively from 1 July 2020, with further reductions of 1% per year from 2023 until reaching a 20% rate from 2027. Additionally, an immediate reduction in the corporate tax rate to 20% is provided for micro small and medium enterprises.
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Serbia Payment procedure: On 25 December 2020, the government released a decree that provides guidelines on the method of paying tax amounts that have been deferred due to the COVID-19 pandemic. The first instalment is due on 10 February 2021 and the remaining on the 10th day of the following months.
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Singapore Incentives-other: On 7 December 2020, Singapore published the Income Tax (Amendment) Act 2020 in the Official Gazette. The Act 2020, grants corporate tax rebate of up to SGD 15,000 to companies affected by the pandemic, exempts certain COVID-19-related pay-outs, and extends the applicable period for certain incentive schemes.
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Sri LankaFiling return: In response to the Covid-19 pandemic, the Inland Revenue Department (IRD) extended the due date for filing the Employer’s Annual Return (PAYE) and Annual Withholding Tax Return (WHT) to 31 January 2021 without penalty for the Year of Assessment 2019/2020 (generally due on 30 April 2020).
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SwedenIncentives for industry/manufacturing: On 17 December 2020, the Swedish Parliament has approved Budget for fiscal year 2021. The Budget includes a temporary tax reduction of 3.9% of the acquisition value of machinery and equipment acquired in 2021 should be introduced for companies and sole traders.
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Thailand Filing return/E-filing: On 15 December 2020, the Thai Revenue Department has published a Notice declaring an extension of the 8-day grace period for electronic filing and payment.
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 USCompensation for overpaid tax and refunds: On 3 December 2020, the Internal Revenue Service announced that interest rates for overpaid and underpaid tax for 1st quarter of 2021 which are unchanged from the previous quarter. Under the Internal Revenue Code, the rate of interest is determined on a quarterly basis. For taxpayers other than corporations, the overpayment and underpayment rate is the federal short-term rate plus 3 percentage points.
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