World Tax Brief: September 2020

Angola	GAAR: The Government Officially published a Law to introduce a general anti-abuse rule allowing the tax authorities to disregard for tax purposes any acts aimed at obtaining a tax advantage with abuse of legal forms, and to apply standards of substance over form and economic reality. See the story in Regfollower
Canada	Due dates main corporate income tax: The Canada Revenue Agency announced that payment deadline for the year 2020 of the income tax returns, including installments for legal entities, trust, and individual is to be extended until 30 September 2020. Late payments of tax due: No penalties and interest will be charged if payments are made by 30 September 2020. See the story in Regfollower PE rules: The Canadian Revenue Agency published a Guidance to further extend the application period until 30 September 2020 on PE rules. See the story in Regfollower
Chile	Thin capitalization rules: The Chilean tax Authority published a Letter to address if interest payments on a loan agreement concluded in 2014 between a Chilean resident company and a non-resident related party would be subject to the thin capitalization rules. See the story in Regfollower
Colombia	PE rules: The Ministry of Finance and Public Credit issued a Decree regarding the permanent establishments and the scope in tax matters of the concepts taxation of investment funds. See the story in Regfollower
Cyprus	Due dates main corporate income tax: The tax department announced to further extends the deadline until 14 January 2021 for tax debt settlements periods that ended by December 31, 2015. Filing return: In addition, the Tax Department also extended the deadline for submitting returns for tax years up to 2015 up to 30 November 2020. See the story in Regfollower
Denmark	Incentives on Industry/manufacturing: The Ministry of Taxation published a draft Bill to increase in the allowed deduction of R&D expenses up to 130% for the 2020 and 2021 tax years to help companies amid COVID-19 pndemic. See the story in Regfollower
Egypt	Late payments of tax due: The Government issued a Law to give waive in case of late payments of tax due. See the story in Regfollower
Finland	Late payments of tax due: The Finnish Tax Authority published updated guidelines on the base and reference rate in regard to interest due for late payment. See the story in Regfollower
France	Treatment of losses: The Government published a Law and announced that companies are allowed to request the immediate refund of their carryback. See the story in Regfollower
Hong Kong	Payment procedures: The Inland Revenue Department announced that taxpayers who faced financial difficulties in settling their tax bills on time may apply to IRD for payment of tax by instalments before the due date of the tax demand notes. See the story in Regfollower
India	Filing return: The Central Board of Direct Taxes of India announced further extension of income tax return for the assessment year 2019-20 until 30 September 2020. See the story in Regfollower
Ireland	Treatment of losses: On 6 August 2020, the Revenue published a new Tax and Duty Manual to provide information to companies on how they may make a claim for the tax loss relief. See the story in Regfollower
Nigeria	Filing return: The Federal Inland Revenue Service made an announcement that the corporate income tax return 2020 is extended until 7 August 2020. See the story in Regfollower
Portugal	Treatment of losses: The Government extended the allowed loss carry forward period to 12 years in respect of losses incurred in the 2020 and 2021 tax years. See the story in Regfollower
Puerto Rico	Filing return: The Treasury Department made postponement on all filing and payment deadlines until 7 August 2020 that were due 31 July 2020 due to Isaias. See the story in Regfollower
Russia	Incentives on Industry/manufacturing: The Government published a Law introducing “ultra-low tax regime” for IT companies, applies from 1 January 2021. Reduced rates: Additionally, this Law provides 3% reduced corporate income tax rate and 7.6% social security contributions for eligible IT companies. See the story in Regfollower
Saudi Arabia	Late payments of tax due: The General Authority of Zakat and Tax of Saudi Arabia issued a release to cancel the fines initiative and exemption from financial sanctions for taxpayers until 30 September 2020 due to the COVID-19 pandemic. See the story in Regfollower
South Africa	Filing return: The South African Revenue Service published a Notice regarding the submission of 2020 income tax returns for both legal entities and natural person. See the story in Regfollower
Sri Lanka	Due dates main corporate income tax: The Inland Revenue Department issued a tax notice regarding first installment of tax payment for the year of assessment 2020-21 by 15 August 2020. See the story in Regfollower
Taiwan	Late payments of tax due: The Finance Ministry issued a Ruling prescribing that certain profit-seeking enterprises may apply for the exemption from their provisional income tax payment during the period until 30 June 2020. See the story in Regfollower
Thailand	Incentives on small business: The Finance Ministry announced tax relief measures for small and medium enterprises (SMEs) in response to the Covid-19 pandemic. See the story in Regfollower Incentives on industry/manufacturing: The Government published Decrees to allow an additional 150% deduction to companies and juristic partnerships for certain investments made in new machinery and hotel renovations. See the story in Regfollower
Ukraine	CFC rules: The Ukraine State Fiscal Service issued a guidance to clarify the taxation of profits of controlled foreign companies (CFCs). The CFC rule in Ukraine will be applicable from 1 January 2021. See the story in Regfollower
United States	CFC rules: The IRS published a revised international practice unit on the Receipt of Dividends or Interest from a related controlled foreign company. See the story in Regfollower