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International Tax | Deloitte tax@hand | 23 October 2020
World Tax Advisor
A world of news with tax@hand.
Luxembourg’s draft 2021 budget law presented to
Chamber of Deputies
The draft law proposes an amendment to the
fiscal unity regime to change from a vertical to a
horizontal consolidation regime, a new real estate
levy that would apply to certain Luxembourg
investment vehicles, and other tax changes and
administrative simplifications.
For the latest developments from various
countries on measures in response to COVID-19,
please visit the Deloitte tax@hand COVID-19
page.
Czech Republic Egypt
Real estate transfer tax abolished Amendments to stamp tax and income
tax laws affect dividends and sales of
The 4% tax on the transfer of real securities
estate has been abolished for
The amendments reduce the
transfers registered on or after 1
withholding tax rate for dividends
December 2019.
paid on listed securities, extend the
exemption from capital gains tax for
transfers of listed securities, and
reduce the stamp tax/duty rates on
securities transactions.
World Tax Advisor Page 1 of 6 © 2020. For information,
23 October 2020 contact Deloitte Touche Tohmatsu Limited.France Hong Kong
R&D tax credit deduction does not Overview of potential implications of
imply transfer of benefit between BEPS Pillar Two proposals
group companies
This article discusses the elements of
A lower tax court decision held that the Pillar Two blueprint that are most
product research costs to be invoiced relevant to groups operating in Hong
by a French company to its foreign Kong and the government’s possible
parent could be determined after domestic policy response.
deducting the R&D tax credit and
provided clarification regarding
comparable data to be used for
transfer pricing purposes.
India India
CBDT issues guidance on application of Legislation enacted to extend
TDS/TCS to e-commerce transactions compliance deadlines and defer some
FA 2020 measures
A circular clarifies the application of
the tax deduction at source and tax The legislation extends the time
collection at source provisions to e- period for paying disputed tax, gives
commerce transactions including statutory effect to the 25% reduction
those conducted through certain in TDS and TCS on specified
exchanges, payment gateways, and payments and receipts, and includes
insurance companies. the deferral of certain provisions
enacted in the Finance Act 2020 as
well as other amendments.
India Ireland
CBDT notifies Faceless Appeal Scheme, Finance Minister announces Budget
2020 2021
World Tax Advisor Page 2 of 6 © 2020. For information,
23 October 2020 contact Deloitte Touche Tohmatsu Limited.Notifications issued by the In addition to providing COVID-19
government set out how the scheme and other relief measures, the budget
will operate to eliminate personal proposes the introduction of interest
interaction during appeal proceedings limitation and anti-hybrid rules,
and clarify the tax authorities’ powers extends the knowledge development
to resolve appeals in accordance with box regime for an additional two
the scheme. years, and subjects sales of IP to
balancing adjustments.
Mexico OECD
Certain tax planning arrangements to Highlights of Pillar One and Pillar Two
be reported retroactively as from 1 blueprints issued for public
January 2021 consultation
Tax advisors and/or taxpayers that This article provides an overview of
designed, implemented, organized, or the Pillar One and Pillar Two
managed tax planning arrangements blueprints that have been approved
that generate a tax benefit in Mexico for public consultation by the
must report the arrangement to the OECD/G20 Inclusive Framework on
tax authorities. BEPS and includes links to relevant
documents.
Portugal Singapore
Implementation of DAC 6 reporting Summary of responses to public
obligations postponed consultations on draft income tax and
GST bills issued
The reporting obligations, which
extend to both cross-border and The public feedback and responses
domestic arrangements and cover primarily address aspects of the bills
taxes not included under the EU that would impose surcharges and
rules, are postponed until 2021. other measures to counteract tax
avoidance arrangements and missing
trader fraud.
World Tax Advisor Page 3 of 6 © 2020. For information,
23 October 2020 contact Deloitte Touche Tohmatsu Limited.United States United States
Disposition of certain partnership Tax function’s role in COVID-19
interests: Highlights of final regulations recovery
The final regulations address the A Deloitte publication discusses three
obligation of transferees to withhold key areas where tax leaders can
10% of the amount realized by deliver strategic value at a pivotal
foreign partners transferring interests time: cash preservation, supply chain
in a partnership engaged in a US planning, and M&A transaction
trade or business on which gain is planning.
taxable.
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World Tax Advisor Page 5 of 6 © 2020. For information,
23 October 2020 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 © 2020. For information, 23 October 2020 contact Deloitte Touche Tohmatsu Limited.
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