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KPMG’s Week in Tax: 23 - 27 March 2020

KPMG’s Week in Tax: 23 - 27 March 2020

Governments and tax authorities across the globe continue to provide tax relief in response to the coronavirus (COVID-19) pandemic.


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KPMG member firms have produced reports based on these developments—all of which can be found on the coronavirus (COVID-19) tax developments page.

To easily find reports by country, read KPMG’s COVID-19, Global Tax Developments Summary [PDF 436 KB] (last updated 25 March 2020)

Other tax developments or tax-related items reported this week include the following.

Transfer Pricing

  • India: Finance Bill, 2020 proposes to expand the scope of the “equalisation levy” to include consideration received by e-commerce operators from e-commerce supply or services, and taxed at a rate of 2%. This levy has an effective date of 1 April 2020.
  • Mexico: The 2020 tax reform includes measures disallowing deductions of payments made to related parties in low-tax jurisdictions and limiting certain interest deductions. These measures have an effective date of 1 January 2020.
  • Denmark: The Danish Ministry of Taxation has proposed changes that would require companies to file the statutory transfer pricing documentation shortly after the tax return is filed (no exemptions seem to apply). Moreover, the legal basis for discretionary assessments would be formally tightened, significantly, in favor of the tax authorities.

Read TaxNewsFlash-Transfer Pricing


  • Germany: The Federal Ministry of Finance issued draft guidance on the application of the mandatory reporting requirements for cross-border tax planning arrangements. As proposed, the rules for the reporting requirements for cross-border tax arrangements would be effective 1 July 2020 in all situations when the first step of a reportable cross-border tax arrangement was implemented after 24 June 2018.
  • Luxembourg: Parliament passed (1) a bill to transpose the amended European Union (EU) directive on administrative cooperation in the field of taxation (DAC 6) into Luxembourg domestic tax law and (2) a bill to ratify a Protocol to amend the existing income tax treaty between Luxembourg and France.
  • Italy: The Supreme Court held that taxpayers that are required to provide bank guarantees in order to obtain refunds of Italian VAT are entitled to a full refund of the amounts of the bank’s guarantee costs.

Read TaxNewsFlash-Europe


  • Nigeria: The Tax Appeal Tribunal issued a decision affirming that the “excess dividend tax” (imposed under section 19 of the Companies Income Tax Act) applies with regard to dividends paid from tax-exempt incomes (such as income derived from bonds, treasury bills, and other short-term government securities).
  • Nigeria: The Federal Inland Revenue Service issued a notice announcing automation of the value added tax (VAT) collection for the wholesale and retail sector.
  • South Africa: During the 2020 budget speech, it was announced that National Treasury is looking to broaden the corporate income tax base—one of the proposed mechanisms would be a restriction on the use of loss carryforwards, limited to 80% of taxable income.

Read TaxNewsFlash-Africa


  • Canada: Concerning the income tax treatment of derivative instruments that involve an underlying capital asset, the Supreme Court of Canada confirmed the relevant framework and specific principles to characterize such gains and losses either as on income account or on capital account.

Read TaxNewsFlash-Americas


  • Netherlands: The Dutch tax administration published a document that provides answers to questions concerning banks that refuse financial services to Dutch nationals under Dutch FATCA legislation.
  • Singapore: The Inland Revenue Authority of Singapore issued updates for “Singapore-based financial institutions” concerning FATCA reporting.
  • Germany: The central tax office (BZSt) released a newsletter as guidance under the FATCA regime.
  • United States: The IRS issued a release announcing updates to a list of “frequently asked questions” concerning consolidated compliance group (CCG) on the FAQ page for qualified intermediaries / withholding foreign partnerships / withholding foreign trusts (QI / WP / WT).

Read TaxNewsFlash-FATCA / IGA / CRS

Exempt Organizations

  • OMB’s Office of Information and Regulatory Affairs (OIRA) received for review proposed regulations concerning an excise tax imposed under section 4960 on the amount of remuneration in excess of $1 million and on any excess parachute payment paid by an applicable tax-exempt organization to a covered employee.
  • The IRS Tax Exempt and Government Entities (TE/GE) division released its “FY 2019 Accomplishments Letter” about the TE/GE’s contributions to the tax administration system and listing each TE/GE function’s accomplishments under six portfolio programs of TE/GE’s compliance program.

Read TaxNewsFlash-Exempt Organizations

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

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