The IRS has been busy on the COVID front, extending reliefs available for qualified opportunity funds (QOFs), in response to the pandemic.
Opportunity zones, created by the 2017 Tax Cuts and Jobs Act, are designed to spur investment in distressed communities through tax benefits. Opportunity zones retain their designation for 10 years and investors may defer tax on almost any capital gain up to December 31, 2026, by making an appropriate investment in a zone, making an election after December 21, 2017, and meeting other requirements.
The regulations allow the deferral of all or part of a gain that is invested into a QOF that would otherwise be includible in income. The gain is deferred until the investment is sold or exchanged, or until December 31, 2026, whichever is earlier. If the investment is held for at least 10 years, investors may … Read More »
In Poland, the implementation of the country’s new ‘Estonia style’ corporate tax system continues apace, with the publication of new forms to be completed by companies seeking to avail themselves of the regime.
On January 1, 2021, Poland introduced a new tax regime for companies whose revenues do not exceed PLN100m (USD26.6m), which provides for an exemption from tax on reinvested profits.
On December 10, 2020, the Ministry released draft guidelines on the new regime, in Polish, including step-by-step instructions, over more than 120 pages, on the process for entering, exiting, and complying with the regime.
And earlier this month, the Polish Government published in its Journal of Laws a regulation including two forms that must be filed to opt into the regime, namely to request to join the regime and to disclose details required regarding the company’s shareholders.
For more information on this, … Read More »
The OECD has revealed that it will be streaming the two-day 11th meeting of the BEPS Inclusive Framework, to be held on January 27-28, 2021.
The OECD explained that opening the event to the public online will allow stakeholders a glimpse into the various international tax-related workstreams undertaken by the Inclusive Framework to date.
One of the key issues that will be under discussion by participants are the tax challenges arising from digitalization and the future of international taxation, including 2021 priorities of the G20.
In October 2020, the OECD released its proposals for reform of international tax rules. Under pillar one of its proposals, new rules will be established on where tax should be paid (“nexus” rules) and there will be a fundamentally new way of sharing taxing rights between countries. The second pillar would introduce a global minimum tax, which the … Read More »
On December 30, the French Government published the 2021 Finance Law in the Official Journal.
This included numerous recently announced corporate tax reliefs, including increasing the annual turnover threshold for small companies to qualify for the 15 percent concessionary rate of corporate tax to EUR10m, from EUR7.63m, with effect from January 1, 2021.
In addition, new Article 2b set new withholding tax bands and rates for non-resident individuals’ employment income for 2021, as follows:
income up to EUR15,018, zero percent;
income thereafter up to EUR43,563, 12 percent (or eight percent for recipients situated in overseas French departments); and
income above EUR43,563, 20 percent (or 14.4 percent for recipients in overseas French departments).
Additional measures included reducing the burden of three local level taxes, and proposals to introduce a VAT group regime, enabling groups of companies to be represented by a single entity for VAT purposes and … Read More »
The OECD has released new guidance for multinational groups and tax agencies on the impact of the COVID-19 pandemic on transfer pricing compliance matters.
The new report, titled ‘Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic’, is intended to address practical questions relating to transfer pricing and is part of the BEPS Inclusive Framework’s commitment to improving tax certainty.
The OECD explained that the guidance is intended to aid both taxpayers in reporting the financial periods affected by the pandemic and tax administrations in evaluating the implementation of taxpayers’ transfer pricing policies. The Guidance provides clarifying comment on, and illustrations of, the practical application of the arm’s length principle in four priority issues, identified in consultation with Business at the OECD (BIAC): comparability analysis; losses and the allocation of COVID-19 specific costs; government assistance programs; and advance pricing agreements.
For more … Read More »