| Australia | Incentive for Industry/manufacturing: On 9 October 2020, the Australian Prime Minister published a press release announcing the approval of the measures for the 2020-21 budgets. To support new investments and increase business cash flow, the government is offering a temporary tax incentive. The government is investing an additional $2 billion through the tax incentive for research and development. Treatment of losses: The government will also allow companies with revenues of up to $ 5 billion to offset losses with previous profits on which taxes have been paid and make a refund. The loss carry forward will be available to around 1 million companies employing up to 8.8 million workers. Losses incurred up to 202 -22 can be attributed to gains made in or after 2018-19. See the story in Regfollower |
| Belgium | Filing return: On 12 October 2020, the Ministry of Finance declared further extension of the deadline for filing corporate income tax (CIT) return to 16 November 2020 for Assessment Year 2020. See the story in Regfollower Carry back losses: Belgium has published a Circular 2020/C/122 regarding guidance on the application of the loss carry back provisions for companies due to the Covid-19 outbreak. To claim the relief, companies are required to comply with Form 275 COV along with their income tax return. See the story in Regfollower |
| Bulgaria | Filing return: On 28 October 2020, the Bulgarian Cabinet approved the 2021 Budget bill drafted by the Finance Ministry at a Cabinet meeting. Accordingly, the annual corporate income tax return deadline is permanently changed from 31 March to 30 June of the following year (30 June deadline provided in 2020 due to COVID-19). See the story in Regfollower |
| Czech Republic | Payment of tax: On 14 October 2020, the Finance Ministry announced that a large liberation packages are extended in response to corona virus pandemic. Accordingly, the automatic deferral applies for all payments of income tax and the deferral applies until December 2020. Treatment of losses: The packages also include the loss relief previously approved that allows companies and individual entrepreneurs to carry back losses incurred in 2020 for offset against taxable profit in 2018 and 2019. With respect to the loss relief, it is provided that taxpayers expecting a loss for 2020 may request a refund (if available after offset) and the refund will be paid as a matter of priority. See the story in Regfollower |
| Egypt | Statute of limitations on tax audit: On 19 October 2020, the President has approved a unified tax procedures law in the Official Gazette. Accordingly, the period in which the Egyptian tax authority can inspect a taxpayer’s books and records is five years from the date of filing the tax return, with the exception of tax evasion cases where the period is six years. Sanctions for non-compliance: The Law also introduced a range of financial penalties for non-compliance with the tax laws as penalty of EGP 3k up to EGP 50k applicable in certain circumstances. See the story in Regfollower Taxation of capital gains: On 30 September 2020, the Egyptian Government has introduced amendments to the taxation of capital gains and dividends distribution tax. Accordingly, Capital gains tax on the capital gains realized by Egyptian and tax-residents from disposing of securities listed on the Egyptian Stock Exchange will be put on hold until the 31st of December 2021 Dividends: Under the amendments, a withholding tax is imposed for dividend distributions by unlisted companies at a 10% rate, while listed companies are subject to a 5% rate regardless of entity exceeds 25% of the share capital or the voting rights; and the participation is held for at least 2 years. See the story in Regfollower |
| France | Taxation of Capital gains: On 28 September 2020, the Council of Ministers passed the Budget Act for 2021. Accordingly, a company that owns real estate can dispose of a sale transaction as part of a sale-and-lease-back transaction and continue to use it as part of a lease agreement. Under the provisions of the 2021 Draft Finance Bill, such sale-and-lease-back contracts would become tax neutral for the company selling its real estate, as it could distribute the capital gain generated over the term of the lease. Incentive for Industry/manufacturing: French tax law also 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. The Bill would also repeal the possibility to file administrative ruling applications regarding the R&D tax credit to agencies in charge of supporting innovation. See the story in Regfollower |
| Greece | Sanctions for non-compliance: On 27 October 2020, the Finance Ministry announced that the filing deadline of the annual certificate of tax compliance is extended from 31 October 2020 to 30 November 2020. See the story in Regfollower |
| Hungary | CFC rule: On 13 October 2020, the Hungarian parliament approved a Bill No. T/13258 to amend the various taxation laws including CFC rules. The bill disallows company income tax exemptions to controlled foreign companies from EU blacklisted jurisdictions on specified capital withdrawals. See the story in Regfollower |
| India | Payment procedures: On 27 October 2020, the CBDT has published a notification extending the deadline (third time) for making payment under the direct tax dispute settlement scheme ‘Vivad Se Vishwas’ by three months to 31 March 2021. See the story in Regfollower Filing return: On 24 October 2020, the Indian Finance Ministry published a notice regarding further extension of due date of furnishing of income tax returns and audit reports as a result of the challenges faced by taxpayers due to the COVID-19 outbreak. See the story in Regfollower |
| Indonesia | Incentive for services: On 1 October 2020, the Directorate-General for Taxation in Indonesia published Regulation No. 143 / PMK.03 / 2020, which extends tax incentives to 31 December 2020 for medical equipment and services necessary to fight the corona virus pandemic. See the story in Regfollower |
| Italy | Payment of tax: On 20 October 2020, Italy has published Decree-Law No. 129 in the Official Gazette announcing urgent measures on tax collection that entered into force on 21 October 2020. Accordingly, payments due by orders of collection agents expiring between 8 March 2020 and 31 December 2020 are extended until 31 January 2021. See the story in Regfollower |
| Luxembourg | Incentives-Others: On 14 October 2020, Luxembourg’s Finance Minister has presented the draft budget law 2020 to the Parliament. The draft budget law introduced a specialized investment funds (SIFs). Under the SIFS, holding real estate assets will be taxed at a 20% rate on their direct and indirect revenue. Additionally, the accelerated amortization rate on new buildings would be decreased from 6% to 4%. See the story in Regfollower |
| Malaysia | Appeal: On 7 October 2020, the Malaysian Inland Revenue Board has published Public Ruling No.7/2020 with the objective to explain the procedures with regard to appeal and application for relief in line with the provisions of the Income Tax Act 1967 and Form Q and Form N appeal procedures. See the story in Regfollower |
| Malta | Incentive for small business: On 19 October 2020, the Minister for Finance presented the Budget for 2021 to the Parliament. Under the budget, a number of Malta Enterprise initiatives on start-ups, online sales for businesses, and even specific schemes for companies employing less than 50 people to enable them to strengthen their online business. See the story in Regfollower |
| Norway | Withholding tax rates: On 7 October 2020, the Norwegian Ministry of Finance announced the state budget for 2021, proposing a 15% withholding tax on interest, royalties and rent payments on certain physical assets paid by companies operating in Norway to affiliates in low-tax countries. In the event of an existence, the effective date would be 1 July 2021. See the story in Regfollower |
| Oman | Late payments of tax due: Recently, the tax authority of Oman declared extensions of certain tax relief measures due to the Covid-19 Outbreak. Previously, in response to the pandemic tax authority has granted relief from the imposition of interest for late payment of tax or late filing of provisional or final tax returns. See the story in Regfollower |
| Poland | Incentive for small business: On 30 September 2020, the Polish lower house of Parliament approved the Bill No.643 that provides for the introduction of an optional “Estonian” corporate income tax (CIT) regime for small and medium enterprises (SMEs). The new tax regime is provided due to the corona-virus pandemic (COVID-19) and will apply from 1 January 2021. See the story in Regfollower |
| Romania | Payment procedures: On 4 October 2020, the Ministry of Finance of Romania declared a tax payment installment option for companies that have been affected by the Covid-19 pandemic. The installment option must be applied for by 15 December 2020 and allows for the payment of tax liabilities up to 12 monthly installments. See the story in Regfollower |
| Spain | GAAR-Rule: On 13 October 2020, the Spanish Council of Ministers approved a draft law on prevention and fight against tax fraud. The bill is presented to the Parliament for its approval. It will enter into force the day after it is published in the Spanish Official Gazette. See the story in Regfollower |
| Turkey | Reduced rates: On 16 October 2020, the Turkish Government has submitted a bill to reduce the Corporate Income Tax rate to lower the corporate tax by up to 5%. See the story in Regfollower |
| Uruguay | Advance payments due: On 14 October 2020, the tax Authority of Uruguay published Resolution No. 1.898/020, extending the deadline for making estimated tax payments of corporate income tax (CIT). See the story in Regfollower |
| Vietnam | Sanctions for non-compliance: On 19 October 2020, the Vietnamese government has issued a decree on sanctioning of administrative violations of tax and invoices. The decree has adapted to the increase in penalties for a number of tax violations and will come into effect on 5 December 2020. The decree sets the amount of the fines for the different violations. See the story in Regfollower Reduced rates: On 15 October 2020, the Vietnamese Government has issued the implementing decree detailing the application of the 30% reduction in the corporate income tax payable for qualified enterprises, cooperatives, agencies and other organizations established under Vietnam laws with the total revenue of not more than VND 200 billion for the year 2020. See the story in Regfollower |
World Tax Brief : November 2020
November 11, 2020
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