Tag Archives: Indien

Steuern International

WORLD TAX ADVISOR 20 November 2020

20. November 2020 Marketing

Asia-Pacific: Regional Comprehensive Economic Partnership agreement signed
Austria: SAC rules third-country insurers and pension funds entitled to dividend WHT refund
France: 2021 draft finance bill would reverse nonresident withholding tax reform proposal
France: Court broadly interprets 50% tax exemption for certain inpatriate investment income
Germany: MOF modifies definition of “supply of goods with installation”
India: CBDT amends deadlines under Direct Tax Vivad se Vishwas Act, 2020
Malaysia: Highlights of Budget 2021 include incentive measures to attract foreign ivestment
Mexico: Legislation proposed to limit subcontracting would have tax implications
Taiwan: Eligibility for deemed profit treatment clarified
United States: IRS guidance addresses deductibility of SALT payments by passthroughs
Uruguay: Government amends investment promotion regime
Tax treaty round up

For the latest developments from various countries on measures in response to COVID-19, please visit the Deloitte tax@hand COVID-19 page.

Steuern International

WORLD TAX ADVISOR 13 November 2020

13. November 2020 Marketing

Australia: Taxpayer wins transfer pricing case in Full Federal Court decision
Albania: Overview of guidance on new fiscalization rules affecting invoicing procedures
Cayman Islands: Portal now available for CRS and FATCA registration and reporting purposes
Cyprus: Tax residence and permanent establishment rules clarified
Czech Republic: Implementation of EU directive provides a new option for tax dispute resolution
France: VAT grouping regime proposed
Germany: COVID-19: Extension of relief measures for certain cross-border commuters
Germany: MOF decree describes filing obligations in connection with extraterritorial taxation
Germany: Upper house of parliament approves ratification of MLI
India: Overview of interaction of equalization levy GST on certain e-commerce supplies
Israel: Draft bill would revise and expand scope of transfer pricing obligations
New Zealand: Inland Revenue guidance on cryptoassets
New Zealand: Tax policy of new government
Singapore: Overview of OECD report on taxation of virtual currencies
United States: A change in course: Tax policy implications of a Joe Biden presidendy

For the latest developments from various countries on measures in response to COVID-19, please visit the Deloitte tax@hand COVID-19 page.

Steuern International

WORLD TAX ADVISOR 6 November 2020

6. November 2020 Marketing

Spain: Digital services tax enacted
Australia: Clarification of the corporate residency test
France: Gifts up to EUR 100,000 temporarily exempted from tax
Guatemala: SAT has begun requesting semented financial statements for transfer pricing purposes
India: High Court rules new tax treaty provision repeals and replaces earlier provision
India: Scope of “faceless” proceedings expanded
Japan: Can Japan attract international financial firms and their high-earning executives?
OECD: New methodology released for BEPS action 13 peer reviews
Oman: VAT Law published
United Arab Emirates: Court allows late payment penalties on voluntary disclosures
United Arab Emirates: Economic substance notification and report templates issued
United States: IRS issues guidance on restricting telescoping in MAP and APA cases
United States: Retirement bill introduced as sequel to SECURE Act

For the latest developments from various countries on measures in response to COVID-19, please visit the Deloitte tax@hand COVID-19 page.

Steuern International

WORLD TAX ADVISOR 23 OCTOBER 2020

23. October 2020 Marketing

Luxembourg: 2021 budget law draft presented to Chamber of Deputies
Czech Republic: Real estate transfer tax abolished
Egypt: Amendments to stamp tax and income tax laws affect dividends and sales to securities
France: R&D credit deduction does not imply transfer of benefit between group companies
Hong Kong: Overview of potential implications of BEPS Pillar Two proposals
India: CBDT issues guidance on application of TDS/TCS to e-commerce transactions
India: Legislation enacted to extend compliance deadlines and defer some FA 2020 measures
India: CBDT notifies Faceless Appeal Scheme, 2002
Ireland: Finance Minister announces Budget 2021
Mexico: Certain tax planning arrangements to be reported retroactively as from 1 January 2021
OECD: Highlights of Pillar One and Pillar Two blueprints issued for public consultation
Portugal: Implementation of DAC 6 reporting obligations postponed
Singapore: Summary of responses to public consultations on draft income tax and GST bills issued
United States: Disposition of certain partnership intetests: Highlights of final regulations
United States: Tax function’s role in COVID-19 recovery

For the latest developments from various countries on measures in response to COVID-19, please visit the Deloitte tax@hand COVID-19 page.

Steuern International

World Tax Advisor 18 September 2020

18. September 2020 Marketing

Netherlands: 2021 budget includes significant corporate income tax changes
Chile: Master file and local file requirements published
Germany: COVID-19: Extension of relief measures for Belgium and France cross-border commuters
Hong Kong: Tax concession for carried interest: Long-awaited proposal released
India: Platform for transparent taxation introduced to reward honest taxpayers
India: Procedure for foreign pension funds to obtain income tax exemption announced
Ireland: Standard VAT rate reduced temporarily
Israel: Ruling on preferred technological enterprise status of entity offering cloud services
Italy: Legislation transposing DAC 6 into domestic law published
OECD: Tax policy reforms 2020 report released
Singapore: Further details of Jobs Growth Incentive (JGI) released
United Arab Emirates: Economic substance regulations amended and replaced
United States: Post-recess guidance update
United States: Tax policy decisions ahead: Implications of the 2020 presidential election
Venezuela: Municipalities ordered to adopt provisions of municipal tax harmonization agreement

For the latest developments from various countries on measures in response to COVID-19, please visit the Deloitte tax@hand COVID-19 page.

Steuern International

World Tax Advisor 7 August 2020

7. August 2020 Marketing

Italy: Supreme Court rules on beneficial owner concept under EU interest and royalties directive
Brazil: Draft Brazilian tax reform bill proposes elimination of PIS/COFINS and creation of federal VAT
Australia: Foreign investment reforms: Draft legislation released by Treasury
Canada: COVID-19: Extension of Canada Emergency Wage Subsidy
Cyprus: EU anti-tax avoidance directive provisions adopted
El Salvador: New requirements effective for report on suppliers, customers, creditors, and debtors
European Union: EU VAT e-commerce package postponed until 1 July 2021
France: Third amended finance bill becomes law
Greece: COVID-19: Clarification of the tax residence status of individuals and legal entities
Hong Kong: Inland Revenue Department issues revised guidance on advance pricing arrangements
India: Losses may be carried forwart and offset after subtrusts convert to subfunds of LLC
Indonesia: Further businesss sectors eligible for tax incentives during COVID-19 pandemic
Spain: Constitutional Court declares certain minimum CIT advantace payments unconstitutional
United Arab Emirates: Economic substande considerations for reporting purposes
United Kingdom: Guidance published on processes for moving goods between Great Britain and the EU
United States: New regulations address carried interests, businesss interst deduction limitation

For the latest developments from various countries on measures in response to COVID-19, please visit the Deloitte tax@hand COVID-19 page.

Steuern International

World Tax Advisor 10 July 2020

10. July 2020 Marketing

Czech Republic: Introduction of tax loss carryback rules approved
Austria: Draft COVID-19 tax stimulus package approved by lower chamber of parliament
Austria: Reduced VAT rate adopted for certain industries affected by COVID-19
Colombia: DIAN rules on nature and tax treatment of branch profits under Colombia-Spain treaty
Denmark: Supreme Court rules in taxpayer’s favor in landmark transfer pricing royalties case
Dominican Republic: Voluntary asset disclosure and tax amnesty program modified
European Union: Optional deferral of DAC 6 reporting deadlines: Overview of member states’ positions
European Union: Scope of state aid temporary framework extended, list of approved measures published
Hong Kong: IRD issues guidance on unified tax exemption regime for funds
India: ITAT rules on treatment of training as educational activity for charitable purposes
New Zealand: R&D tax credits – Latest developments and key considerations
United States: New coronavirus (and other) guidance issued
United States: Trading partners to proceed with digital tax discussions, with or without the US

For the latest developments from various countries on measures in response to COVID-19, please visit the Deloitte tax@hand COVID-19 page.

Steuern International

World Tax Advisor 15 May 2020

15. May 2020 Marketing

The World Tax Advisor includes in particular a special COVID-19 section:

Peru: Peru extens tax loss carryforward period for corporations in response to COVID-19
Belgium: Additional agreements concluded to manage COVID-19 impact on cross-border workers
Bermuda: Economic substance declaration portal now available
Brazil: COVID-19: Tax and other financial measures approved
China: Enterprise income tax incentive extended in western regions
European Union: CJEU rules on independent EU subsidiary as VAT fixed establishment of non-EU parent
European Union: European Commission proposes extensions of DAC 6 reporting deadlines
Hong Kong: IRD issues updated guidance on advance rulings
India: CBDT relaxes individual residency rules for FY 2019-20 in light of COVID-19 lockdown
India: Supreme Court rules evidence in penalty proceedings valid to determine assessment
New Zealand: What impact will COVID-19 travel restrictions haven on your company’s tax residence?
OECD: Concerns over unilateral DSTs grow as OECD tax overhaul project faces possible delay
United States: More Paycheck Protection FAQs and other guidance released

Steuern International

World Tax Advisor 24 April 2020

24. April 2020 Marketing

The World Tax Advisor includes in particular a special COVID-19 section:

Australia: Jobkeeper scheme: Racing the clock
Canada: COVID-19 – Recent support announcements
Canada: COVID-19 – The new Canada Emergency Response Benefit
Colombia: Simplified and accelerated procedure for requesting tax refunds or offsets introduced
Costa Rica: Tax relief measures enacted in response to COVID-19
Cyprus: Changes to VAT periods and deadlines for submission of returns and payment of VAT
India: FDI policy change to restrict opportunistic takeovers of domestic companies announced
India: CBDT clarifies extensions to lower or nil TDS/TCS certificates for FY 2020-21
Korea: Tax reform measures enacted in response to COVID-19
Kuwait: Government announces extension of public holiday beyond tax filing deadline
New Zealand: COVID-19: The latest tax announcements
OECD: Individual residency and taxation for stranded workers due to COVID-19
OECD: Report presented to G20 on how tax policy can help governments deal with COVID-19
Peru: Clarification provided that deadline extensions apply to temporary net assets tax
Saudi Arabia: VAT return and payment deadlines extended due to COVID-19
Singapore: Managing GST compliance and cashflow during COVID-19
Switzerland: SFTA modifies its approach to net tax rate scheme due to COVID-19
Taiwan: Annual income tax return filing and payment period extended
Thailand: Tax relief measures announced in response to COVID-19
United Arab Emirates: Economic substance considerations in light of COVID-19
United States: Update on US global trade regulatory developments in response to COVID-19
United States: Summary of employer payroll tax relief
United States: Additional coronavirus guidance, resource materials available
Venezuela: Measures in response to COVID-19 include tax exemptions for certain imported goods
Bahrain: Guidance on mutual agreement procedure issued
El Salvador: Deadline approaching for appointment of tax auditors for 2020 tax period
Guatemala: Changes to taxation of international air transportation industry coming in 2021
India: Certain Mauritius FPIs not covered under indirect transfer income deeming provisions
India: CBDT clarifies that employers may apply simplified tax regime for withholding taxes
United Arab Emirates: Foreign businesses may submit 2019 VAT refund requests
United States: Deloitte Tax looks at final, proposed hybrid regulations
United States: IRS releases transfer pricing documentation “frequently asked questions”
Venezuela: Value of tax unit adjustment
Tax treaty round up

Steuern International

World Tax Advisor 10 April 2020

10. April 2020 Marketing

The World Tax Advisor includes in particular a special COVID-19 section:

Australia: R&D uplifts available on accelerated depreciation and (most) IAWOs
Bahrain: Economic substance reporting deadline extended
Belgium: Certain income tax prepayment credit percentages increased in view of COVID-19
Brazil: COVID-19: Latest tax measures approved by government
Canada: COVID-19 – Recent government support measures
Colombia: Local authorities adopt new tax compliance deadlines and tax cuts in view of COVID-19
El Salvador: Additional legislation enacted in response to COVID-19
European Union: Commission approves French, Spanish aid schemes for companies affected by COVID-19
Greece: COVID-19 – Third package of measures announced
India: Ordinance effects extended tax compliance deadlines announced in response to COVID-19
Indonesia: Measures introduced in response to COVID-19 include immediate CIT rate reduction
Israel: Tax filing deadlines postponed under COVID-19 emergency regulations
Italy: Measures introduced in response to COVID-19 include various incentives
Japan: FAQs clarify relief available for taxpayers affected by COVID-19
Luxembourg: Financial aid scheme established for enterprises affected by COVID-19
New Zealand: R&D tax credit – Broader refundability for loss making companies
New Zealand: Cross-border workers and tax considerations resulting from COVID-19
Norway: Government implements financial support program
OECD: OECD issues recommendations on implications of COVID-19 on cross-border matters
Peru: Postponement of deadlines for certain tax obligations extended and expanded
Qatar: Government temporarily exempts 905 items from customs duties in response to COVID-19
Russia: 15% dividend and interest WHT rate to apply to recipients in conduit jurisdictions
Singapore: Resilience budget to ease financial consequences of COVID-19 for taxpayers announced
South Africa: Update on tax developments in response to COVID-19
United Arab Emirates: Update on economic substance notification deadlines
United Kingdom: New guidance on execptional circumstances for UK residence test in view of COVID-19
United States: Understanding the CARES Act’s tax provisions – A selected list of key resources
United States: Penalty relief for failure to deposit employment taxes linked to COVID-19 tax credits
Hong Kong: Tax authorities issue updated guidance on taxation of e-commerce transactions and digital assets
Cambodia: Guidance clarifies TOS exemption on 2020 seniority indemnity payments
European Union: CJEU clarifies application of EU parent-subsidiary directive to Gibraltar
European Union: CJEU AG opines on VAT treatment fo investment fund management services
India: Parliament enacts Finance Act 2020, amends certain Finance Bill 2020 proposals

Steuern International

World Tax Advisor 3 April 2020

3. April 2020 Marketing

The World Tax Advisor includes in particular a special COVID-19 section:

Albania: Certain tax deadlines for small businesses extended, among other COVID-19 measures
Argentina: Tax measures introduced in response to COVID-19
Australia: Federal government announces significant foreign investment approval changes
Australia: JobKeeper scheme announed to maintain employment levels
Belgium: VAT credit refund possibility announced in response to COVID-19
Bermuda: CRS and CbC reporting deadlines extended due to COVID-19
British Virgin Islands: Information exchange, economic substance frameworks to be maintained during COVID-19
Canada: COVID-19 – Update on fiscal measures
China: Summary of tax relief measures relevant to COVID-19
Colombia: COVID-10 measures include increased powers for local government, VAT exemptions
Cyprus: COVID-19 tax and VAT measures voted
El Salvador: Special decrees and laws on tax matters issued in response to COVID-19
European Union: Commission approves German direct grant scheme for companies affected by COVID-19
France: Government eases tax rules cross-border employees working remotely
India: Tax and regulatory compliance deadlines extended in response to COVID-19
Indonesia: New fiscal measures announced in response to COVID-19
Japan: Effect of COVID-19 on transfer pricing
Kosovo: Extension of tax filing deadlines in response to COVID-19
Mexico: Various tax measures proposed to mitigate economic impact of COVID-19
Netherlands: Measures announced in response to COVID-19 include tax deferrals
New Zealand: COVID-19 Response (Taxation and Social Assistance Urgent Measures) Act 2020
Norway: Parliament adopts measures in response to COVID-19
OECD: Platform for Collaboration on Tax launches new website including COVID-19 resources
Portugal: COVID-19 – Support measures for companies and employees
South Africa: Tax relief measures announced in response to COVID-19
United States: COVID-19 stimulus: A taxpayer guide
India: Equalization levy on e-commerce supply or services introduced
Cambodia: TOI exemption granted to businesses impacted by suspension of EBA scheme
France: New guidelines for non-EU exporters released
France: Supreme Court rules self-employed status of digital platform worker is “fictional”
India: Mandatory e-invoicing for GST purposes deferred until 1 October 2020
Qatar: Directives published on mutual agreement procedures
Singapore: Foreign worker hiring ratio to be cut in three sectors as from 2021
United States: Deadline unchanged to apply for quick refund of overpayment of estimated tax
Uruguay: Companies involved in restructuring may elect tax-free treatment for goodwill

Steuern International

World Tax Advisor 20 March 2020

20. March 2020 Marketing

The World Tax Advisor includes in particular a special COVID-19 section:

Autralia: Administrative measures on international tax issues in response to COVID-19 announced
Australia: Government accounces business support measures in response to coronavirus
Belgium: COVID-19 implications for taxation of cross-border workers
Canada: Fiscal measures to support the economy
Columbia: Tax measures announced in response to COVID-19
Cyprus: Direct tax and VAT measures in response to COVID-19 announced
Indonesia: Changes in working practices in response to COVID-19 affect tax services
Italy: Urgent tax measures adopted in response to COVID-19
Jersey: Guidance on COVID-19 and economic substance issued
New Zealand: COVID-19 – Tax reform measures included as part of Business Continuity Package
Taiwan: Various filing and payment deadlines extended in response to COVID-19
United States: Senate approves coronavirus stimulus package
India: AAR denies capital gains exemption under tax treaty with Mauritius
Australia: ATO view of associate test prevails
Canada: 2020-2021 Quebec budget highlights
Cayman Islands: FATCA and CRS changes introduced for 2019 reporting year
France: DAC 6: First FTA guidelines published
Germany: Guidance issued on guaranteed minimum payments in tax consolidated group
Germany: MOF publishes first draft of decree for application of DAC 6 rules
Luxembourg: Tax authorities release guidance on CFC rules
Peru: Branches of foreign entities not subject to additional tax on indirect distributions

Steuern International

World Tax Advisor 6 March 2020

6. March 2020 Marketing

The World Tax Advisor includes in particular:

Malaysia: Malaysian tax legislation enacted, including changes affecting Labuan entities
Australia: Australia prognoses expanded definition of significant global entity
El Salvador: Tax and customs amnesty available
Germany: MOF publishes list of preferential tax regimes for purposes of royalty barrier rule
Greece: Offsetting pharmaceutical expenditure clawbacks with R&D and investment expenses
Hong Kong: 2020/21 budget contains limited tax measures
Hong Kong: Concessionary measures for ship leasing businesses announced
India: New provisions allow takeover offers by majority shareholders of unlisted companies
Israel: Supreme Court rules on calculation of taxable capital gain on sale of foreign shares
Norway: Consultation paper considers WHT on nonresident related party interest and royalties
OECD: Input requested on draft model reporting rules for sharing and gig economy platforms
United States: G-20 leaders express support for OECD project but hurdles remain

Steuern International

World Tax Advisor 7 February 2020

7. February 2020 Marketing

The World Tax Advisor includes in particular:

OECD: OECD issues statement on two-pillar approach to tackling tax challenges of digitalization
Ukraine: Ukraine parliament adopts BEPS tax reform measures
Australia: ATO focus on cross-border intangible transactions
European Union/Belgium: CJEU rules Belgian stock exchange tax is not contrary to EU law
European Union/Netherlands: Dutch requirements for refund of divided WHT to nonresident FIIs may breach EU law
European Union: European Commission publishes annual survey on tax policies in the EU
Finland: Tax authorities issue guidance on new rules for investment funds’ tax-exempt status
France: 2020 finance law includes changes to VAT rules
Greece: Taxation of dividends clarified
India: Highlights of 2020/21 budget for nonresidents
Netherlands: Supreme Court defines “mutual funds” for WHT purposes
United States: OECD endorses international tax rewrite efforts, punts on US “safe harbor” proposal

Steuern International

World Tax Advisor 24 JANUARY 2020

24. January 2020 Marketing

The World Tax Advisor includes in particular:

Curacao: Curacaos new tax legislation introduces territorial tax system
Belgium: Dividends received deduction continues to apply for Swiss dividends
Belgium: Amendments to interest deduction limitation rule enacted
Bermuda: Amended legislation and final guidance on economic substance released
Brazil: Stricter thin capitalization rules apply on interest paid to Dutch holding company
India: High Court rules payments for satellite and other broadcasting services are not FTS
Luxembourg: New exit tax rules enter into force
Taiwan: Three options available to reduce WHT burgen on technical service fees
United Kingdom: Final regulations on EU mandatory disclosure rules published

Steuern International

World Tax Advisor 17 JANUARY 2020

17. January 2020 Marketing

The World Tax Advisor includes in particular:

Ecuador: Ecuador enacts Tax Simplicity and Progressivity Law
Argentina: Tax reform measures enacted
Barbados: Nonresident suppliers now required to collect VAT on certain online transactions
Cambodia: Financial Management Law amended
Colombia: Amended tax reform legislation enacted
India: Amalgamated companies’ revised returns submitted after statutory deadline are valid
Israel: Reportable tax positions for FY 2019 tax returns published
Italy: 2020 budget law enacted, related law decree converted into law
Jersey: Draft regulations to implement mandatory disclosure rules issued
United Arab Emirates: Further guidance on economic substance rules released
United States: Tensions continue over French digital services tax, US tariff threats
United States: Summary of Taxpayer Certainty and Disaster Relief Act of 2019
United States: 2019 IRS report addresses enforcement programs and emerging compliance issues

Steuern International

World Tax Advisor 10 January 2020

10. January 2020 Marketing

The World Tax Advisor includes in particular:

Israel: Israeli Court rules business model change not necessarily sale of functions, assets and risks
European Union: CJEU rules Belgian participation exemption applied with NID infringes EU directive
France: 2020 finance bill becomes law
Germany: Draft law includes long-awaited reform of CFC rules
Germany: Legislation to enact significant changes to transfer pricing rules introduced
India: Company law tribunal rejects scheme of arrangement involving outbound demerger
India: Legislation introducing reduced concessional tax rates and other reliefs enacted
Luxembourg: ATAD 2 implemted into domestic law
Luxembourg: Pre-2015 advance tax decisions cease to have effect from end of 2019 tax year
Qatar: New regulations amend income tax law and introduce transfer pricing requirements
United States: Deloitte Tax summarizes proposed regulations under sections 863-865
United States: Tresury, IRS release section 162(m) proposed regulations
United States: Congress approves tax relief and spending legislation

Steuern International

World Tax Advisor 15 NOVEMBER 2019

15. November 2019 Marketing

The World Tax Advisor includes in particular:

OECD: OECD releases public consultation document on global anti-base erosion proposal
Brazil: President ratifies cooperation agreement with OECD
European Union: Belize removed from EU list of noncooperative jurisdictions
Hong Kong: Tax reduction measure passed by Legislative Council
India: ITAT rules AOP is taxable at rate applicable to foreign company
India: WTO recommends withdrawal of various export promotion measures
India: ITAT rules expenditure attributable to issue of bonus shares is revenue in nature
Ireland: Finance Bill 2019 overhauls transfer pricing regime
New Zealand: Inland Revenue releases Multinational Compliance Focus document
United States: IRS releases guidance on transition away from LIBOR
United States: Another stopgap spending bill looks likely as government funding deadline approaches

Steuern International

World Tax Advisor 28 June 2019

28. June 2019 Marketing

The World Tax Advisor 21 June includes in particular:

Japan: Japan’s enhanced earnings stripping rules align with action 4 of BEPS project
Brazil: Tax treaty signed with Uruguay
European Union: CJEU rules on applicable social security system for activities performed outside EU
Germany: BFH asks CJEU ro rule on scope of VAT exemption for commercial education services
India: GST Council recommends further extension of GST return filing deadline for 2017-18
Italy: Supreme Court rules on tax residence of holding company
Malaysia: Update on implementation of service tax on imported digital services
OECD: MLI matching database expanded, more countries sign/deposit ratification instruments
United States: Ninth Circuit Court of Appeals reverses Tax Court in Altera
United States: New regulations addressing GILTI issues, foreign tax credits, section 245A summarized
United States: Joint Committee on Taxation releases overview of Qualified Opportunity Zones
Tax treaty round up

Steuern International

World Tax Advisor 24 November 2017 – Connecting you globally

23. November 2017 Georg Erdélyi

The World Tax Advisor 24 November 2017 includes in particular:

French amended finance law and bill for 2017 contain measures affecting companies
Ecuador: Tax haven jurisdictions defined
Germany: Capital gains from sale of shares by non-treaty-protected shareholder are fully tax-exempt
Germany: Final decree issued on withholding tax on outbound payments for software and database usage

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