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International Tax | Deloitte tax@hand | 6 August 2021
World Tax Advisor
A world of news with tax@hand.
China’s STA issues simplified procedures for
unilateral APAs
The State Taxation Administration has issued simplified
procedures for unilateral advance pricing arrangements for
certain enterprises, which include fewer steps in the process
and time limits for the tax authorities to review applications
and conduct negotiations.
Updated German transfer pricing principles
provide new MOF guidance on financing
structures
The Ministry of Finance has provided new guidance regarding
intercompany loans by a foreign financing company to a
German borrower, which provides that the interest rate on a
loan from a foreign financing company must be determined
based on a risk-free market return, unless the foreign
financing company has the ability and authority to control the
investment of the funds and bear the financial risk.
For the latest developments from various countries on
measures in response to COVID-19, please visit the Deloitte
tax@hand COVID-19 page.
World Tax Advisor Page 1 of 6 © 2021. For information,
6 August 2021 contact Deloitte Touche Tohmatsu Limited.Cambodia China
Tax authorities confirm application IIT subsidy measures updated in the
of mutual agreement procedure Greater Bay Area
This article describes the mechanism for The municipalities in the Greater Bay Area
applying the mutual agreement procedure have updated their administrative measures
under Cambodia’s tax treaties, which provides and application guidelines for obtaining
a dispute resolution process to resolve tax individual income tax subsidies for qualified
treaty-related disputes. talent for the period from 2019 through 2023,
to make obtaining a subsidy easier and more
convenient.
Germany Germany
MOF guidance updates VAT New taxes introduced on online
treatment of supervisory board poker and virtual slots affect
members gambling organizers
The Ministry of Finance has published a New special taxes on online poker and virtual
circular that updates the VAT treatment of slot machine games that apply to organizers of
members of an entity’s supervisory board; the online gambling have been introduced along
circular provides that members who do not with the legalization of online gambling and
bear any remuneration risk because they the extension of existing concessions.
receive non-variable fixed remuneration are
not self-employed and are not acting as
taxable persons for purposes of the VAT rules.
World Tax Advisor Page 2 of 6 © 2021. For information,
6 August 2021 contact Deloitte Touche Tohmatsu Limited.Greece Hong Kong
Important VAT law changes Guidance released on tax issues
enacted arising from the COVID-19
pandemic
VAT legislative amendments have been
published and include provisions that The Inland Revenue Department has released
incorporate into domestic legislation various guidance on the effects of the COVID-19
EU directives on e-commerce transactions and pandemic on tax residence, permanent
that extend the applicability of special reduced establishments, employment income, and
VAT rates for certain Greek islands, among transfer pricing issues; the guidance generally
other modifications. aligns with tax guidelines issued by the OECD.
India India
Deemed dividend provisions do not Recent developments increase
apply when company derives prospect of India-UK free trade
benefit from shareholder agreement
The Karnataka High Court has ruled that The Indian and UK prime ministers have agreed
deemed dividend provisions that treat loans or on an enhanced trade partnership and
advances by closely held Indian companies to announced their intention to negotiate a
certain shareholders as dividends do not apply comprehensive free trade agreement, as well
where the company derives a benefit from the as agreeing to continue to remove trade
shareholder based on the grant of the loan or barriers.
advance.
World Tax Advisor Page 3 of 6 © 2021. For information,
6 August 2021 contact Deloitte Touche Tohmatsu Limited.Italy Korea
Ministerial tax guidance clarifies Government proposes tax
treatment of employment income incentives to encourage domestic
in the COVID-19 era investment
The tax authorities have published guidance The government has announced tax proposals
that sets forth some relevant principles to encourage companies to return
relating to the tax treatment of employment manufacturing operations from foreign
income in light of the COVID-19 pandemic; the countries to Korea and to invest in domestic
guidance covers topics including the semiconductor technologies.
reimbursement of certain employee expenses
and the remuneration of outbound assigned
employees that returned to Italy due to COVID-
19.
OECD United States
New statistics indicate downward Taxwriting chairs eye limits on
trend in statutory corporate income “mega-IRAs”
tax rates
Legislators have announced that they intend to
The OECD has released a publication and pursue legislation aimed at tightening the rules
database that reflect findings of a downward governing certain contributory individual
trend in statutory corporate income tax rates retirement accounts, in an effort to prevent
over the last two decades, as well as evidence wealthy investors from using such accounts as
of continuing base erosion and profit shifting a tax planning tool rather than a traditional
behaviors. retirement savings vehicle.
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World Tax Advisor Page 5 of 6 © 2021. For information,
6 August 2021 contact Deloitte Touche Tohmatsu Limited.About Deloitte Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities (collectively, the “Deloitte organization”). DTTL (also referred to as “Deloitte Global”) and each of its member firms and related entities are legally separate and independent entities, which cannot obligate or bind each other in respect of third parties. DTTL and each DTTL member firm and related entity is liable only for its own acts and omissions, and not those of each other. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte is a leading global provider of audit and assurance, consulting, financial advisory, risk advisory, tax and related services. Our global network of member firms and related entities in more than 150 countries and territories (collectively, the “Deloitte organization”) serves four out of five Fortune Global 500® companies. Learn how Deloitte’s approximately 312,000 people make an impact that matters at www.deloitte.com. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms or their related entities (collectively, the “Deloitte organization”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No representations, warranties or undertakings (express or implied) are given as to the accuracy or completeness of the information in this communication, and none of DTTL, its member firms, related entities, employees or agents shall be liable or responsible for any loss or damage whatsoever arising directly or indirectly in connection with any person relying on this communication. DTTL and each of its member firms, and their related entities, are legally separate and independent entities. World Tax Advisor Page 6 of 6 © 2021. For information, 6 August 2021 contact Deloitte Touche Tohmatsu Limited.
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