| Argentina | Incentives for small business: On 17 May 2021, the Federal Administration of Public Revenue (AFIP) published a General Resolution 4992/2021 of 17 May 2021 to extend a payment facility for small and medium enterprises (SMEs). This payment facility was scheduled to expire in 2020. Due to the COVID-19 outbreak, the facility is now extended until 31 August 2021. See the story in Regfollower Main corporate tax rate: On 20 May 2021, Argentina’s the Chamber of Deputies approved a bill. The bill is introduced new progressive corporate income tax rates from 1 January 2021. This includes the replacements of the single 25% rate with the following progressive rates on net taxable income: • up to ARS 5,000,000: 25% • over ARS 5,000,000 and up to 50,000,000 : 30% • over 50,000,000 : 35%. Withholding tax on dividends: This Bill also proposed a reduction of the withholding tax rate on dividends from 13% to 7% as from 1 January 2021. See the story in Regfollower |
| Thailand | Filing return: On 30 April 2021, the Thai Ministry of Finance announced an extension of the deadline for filing the annual corporate income tax return (PND.50) and for paying the related tax to 30 June 2021 from May 2021 in response to the Covid-19 pandemic. See the story in Regfollower |
| Belarus | PE rules: On 29 April 2021, the Tax and Duties Ministry of the Republic of Belarus has issued a Guidance to clarify the taxation of foreign organizations operating in the territory of the Republic of Belarus through permanent establishments (PEs). The Guidance also clarifies the registration of foreign organizations and specifics the submission of tax returns and Corporate Income Tax obligations. See the story in Regfollower |
| Czech Republic | Sanction for late payment: On 22 April 2021, the Ministry of Finance issued a guide in Financial Bulletin 19/2021, which provides amendments to the Tax Code. According to the Guide, the late payment interest rate is decreased from 14% to 8%. The amount of default interest is equal to 14% plus the repo rate set by the Czech National Bank applies up to 31 December 2020 as on the first day of the relevant calendar half-year. From 1 January 2021, the new interest rate of 8% plus the repo rate will be used on the first day of the relevant calendar half-year, while the method of calculation is unchanged. See the story in Regfollower |
| Denmark | CFC rule: On 23 April 2021, the Ministry of Taxation announced a public consultation for amending a draft Bill L 89. This Bill proposes for an Act amending the Corporation Tax Act and the Capital Gains Tax Act (Implementation of the minimum requirements of the Tax Avoidance Directive to the CFC rules of the Member States). The current draft amendment provides for a partial substance test in relation to the inclusion of other income from intangible assets as CFC income. See the story in Regfollower |
| Hungary | Filing return: On 21 April 2021, the Finance Ministry of Hungary published a Decree extending filing deadlines for all major business income tax returns due to COVID-19. Accordingly, annual returns for corporate income tax, local business tax, and energy suppliers’ income tax will be due September 30 rather than May 31. Companies must make any outstanding tax payments by September 30. See the story in Regfollower |
| Kenya | PE rules: On 5 May 2021, the Parliament of Kenya has published the finance bill 2021. The bill proposes to repeal the current definition of “permanent establishment” (PE) and introducing a new definition that adapts to the international best practices of the OECD and UN model tax treaties as well as the BEPS project. Carry forward of losses: The Bill proposes to omit the 10-year time limitation. If the Bill is passed, taxpayers will utilize a tax loss arising in a year of income to reduce taxable business income in subsequent years indefinitely. Statute of limitations: The Bill also proposes to extend the time period that a taxpayer is required to maintain their records from 5 to 7 years. See the story in Regfollower |
| Peru | Thin capitalization rule: On 12 May 2021, the Peruvian Tax Administration (SUNAT) has issued a Resolution regarding various queries related to the application of the limit for the deduction of interest expenses. The Guideline clarifies interest deduction for thin capitalization rules. See the story in Regfollower |
| South Africa | Dividend income: On 17 May 2021, the South African Revenue Service issued an update Interpretation on the taxation of foreign dividends. This Note provides guidance on the interpretation and application of various provisions of the Act relating to foreign dividends. See the story in Regfollower |
| Turkey | Filing return: On 3 May 2021, the Turkish Revenue Administration has issued Circular No. 134, which extends the submission and payment periods of the Income and Corporate Provisional Tax Returns for 2021. See the story in Regfollower |
| UAE | Sanction for tax evasion: On 28 April 2021, the Cabinet of Ministers issued Resolution No. 49/2021, which amends a previous Cabinet Resolution in relation to administrative penalties for the violation of tax laws in the UAE. Cabinet Resolution No. 49/2021 enters into force 60 days following its issuance. See the story in Regfollower |
World Tax Brief: June 2021
June 21, 2021
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