International Tax News. Edition 86 May 2020€¦ · Welcome Bernard Moens Global Leader...
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International Tax News Edition 86 May 2020 www.pwc.com/its
Transcript of International Tax News. Edition 86 May 2020€¦ · Welcome Bernard Moens Global Leader...
International Tax NewsEdition 86May 2020
www.pwc.com/its
Keeping up with the constant flow of international tax developments worldwide can be a real challenge for multinational companies. International Tax News is a monthly publication that offers updates and analysis on developments taking place around the world, authored by specialists in PwC’s global international tax network.
We hope that you will find this publication helpful, and look forward to your comments.
Welcome
Bernard Moens Global Leader International Tax Services Network T: +1 703 362 7644E: [email protected]
Featured articles
Responding to the potential business impacts of COVID-19 COVID-19 can cause potentially significant people,
social and economic implications for organisations.This link provides information on how you
can prepare your organisation and respond.
In this issue
Legislation Administrative Judicial Treaties
Legislation
China extends preferential CIT policies for development of the Western Regions
The prevailing fiscal incentives for China’s Western Region will expire at the end of 2020. The relevant Chinese government authorities, on April 23, 2020, jointly issued Public Notice [2020] No.23, extending the preferential corporate income tax (CIT) policies to further support the country’s go-west strategy. Specifically, qualified enterprises from encouraged industries in the Western Regions are eligible for a reduced CIT rate of 15% (the statutory CIT rate is 25% in China) from January 1, 2021 to December 31, 2030.
‘Western Region’ covers one municipality (Chongqing), six provinces (Gansu, Guizhou, Qinghai, Shaanxi, Sichuan and Yunnan) and five autonomous regions (Guangxi, Inner Mongolia, Ningxia, Tibet and Xinjiang). Tax policies in three other autonomous prefectures in Hunan, Hubei and Jilin provinces can refer to those for the Western Region. Enterprises claiming this preferential treatment should self assess their eligibility, account for the reduced CIT rate in the provisional CIT filing, and prepare relevant documents for the tax authorities’ post-filing examination.
Long Ma
China
T: +86 10 6533 3103E: [email protected]
China
PwC observation:The extended preferential CIT policies demonstrate the Chinese government’s determination to further promote the Western Region’s development and narrow the economic gap between the country’s eastern and western areas. Foreign investors are also encouraged to consider this when planning to expand their investment in China.
European Commission proposes to defer DAC2/DAC6 deadlines
Due to the COVID-19 pandemic, the European Commission (EC) published a proposal on May 8 for a Council Directive amending Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC). The proposed Directive defers reporting and exchanging of information deadlines for financial account information under DAC2 (the EU Common Reporting Standard, or CRS) and for mandatory disclosure rules under DAC6.
The EC’s proposal includes the following amendments:
• Defer the time limit for EU Member States’ exchanges of information on reportable financial accounts under DAC2 by three months, i.e., until December 31, 2020.
• Change the date for the first exchange of information between EU Member States on reportable cross-border arrangements under DAC6 by three months, i.e., from October 31, 2020 to January 31, 2021.
• Change the beginning date of the 30-day period for reporting on reportable cross-border arrangements by intermediaries (or taxpayers) under DAC6 by three months, i.e., from July 1, 2020 to October 1, 2020.
• Change the date for reporting ‘historical’ reportable cross-border arrangements (i.e., arrangements in the period from June 25, 2018 through June 30, 2020) by intermediaries (or taxpayers) under DAC6 by three months, i.e., from August 31, 2020 to November 30, 2020.
Please see our PwC Insight for more information.
Edwin Visser
Sydney
T: +31 6 2294 3876E: [email protected]
Astrid Bauer
Germany
T: +49 171 333 9 705E: [email protected]
Maarten Maaskant
United States
T: +1 347 449 4736E: [email protected]
EU
PwC observation:The proposed deferrals merely extend the deadline for complying with DAC2 and DAC6 obligations while ensuring the eventual exchange of all reportable information. The periods to which the reportable information pertains will not change. Taxpayers and intermediaries operating in the European Union should understand the importance and impact of DAC6. Impact assessment, analysis and timely action are needed to ensure compliance on and after July 1, 2020. There are significant penalties for non-compliance.
COVID-19: Spanish tax measures
Due to the Covid-19 pandemic, Spain has been in a state of emergency since March 14. The Spanish government adopted several measures to address the pandemic’s economic and social impact. The most significant measures include the temporary suspension of employment contracts (expediente de regulación temporal de empleo, or ERTE), and the reduction of working hours due to force majeure contract causes.
Spain has not adopted major tax measures to help multinational companies withstand the lack of activities and revenue.
Royal Legislative Decree 15/2020, in force since April 23, allows advance income tax payment calculations (i.e., pagos fraccionados) to be based on the proportional taxable base of the tax year, as opposed to the base on the previous fiscal year’s tax quota. Taxpayers whose tax year began on or after January 1, 2020 with a turnover (i.e., ‘volumen de operaciones’ as defined by the Spanish VAT law) in 2019 of less than 600,000 euros should choose the option when filing the first advance income tax payment within the legal extended deadlines (i.e., May 20, 2020), while those taxpayers with a turnover in 2019 of less than 6,000,000 euros (except for taxpayers within
a tax consolidation group), should choose the option when filing the second advance income tax payment within the legal deadline (i.e., October 20, 2020). The payment of the period when the option is made should also be calculated following the proportional taxable base rules.
Separately, Royal Decree-Law 17/2020, in force since May 7, approves measures to support the cultural sector. Among others, it establishes a five-point increase in the tax credit for investments in film productions effective for fiscal years that start on or after January 1, as well as an increase in the tax credit limit from 3 million euros to 10 million euros.
Lastly, Royal Decree-Law 18/2020, in force since May 13, establishes that certain companies in a temporary suspension of employment contracts are not allowed to distribute dividends corresponding to the fiscal year when the suspension is applied, except if the company previously paid the exonerated social security amount.
For other previously adopted tax measures in connection with the Covid-19 pandemic, please see the April 2020 of International tax News.
Spain
Roberta Poza Cid
Madrid
T: +34 915 684 365E: [email protected]
Isabel Asin Perez
Madrid
T: +34 91 568 5358E: [email protected]
PwC observation:The tax measures adopted by the Spanish government are subject to certain requirements in terms of previous year turnover and application of special tax regimes. Multinationals with entities in Spain must review in detail such requirements to check whether the measures apply.
COVID-19 support package for innovative firms
HM Treasury on April 20, 2020 launched a billion-pound support package for innovative firms impacted by coronavirus. Whether companies are investing in new R&D projects or focused on surviving in the current climate, this new package aims to ensure that Britain remains a global leader in innovation. The support package is split into two elements:
• A £500m growth scheme for high growth businesses, called the Future Fund, designed to ensure high-growth companies across the UK receive the investment they need to continue during the crisis.
• Targeted support of £750m for the most R&D-intensive SMEs (small and medium-sized enterprises) will be available through Innovate UK’s grants and loan scheme.
The Future Fund will be delivered in partnership with the British Business Bank and launched in May. The fund will provide UK-based companies with loans between £125,000 and £5m from the government, with private investors at least matching the government commitment. These loans will automatically convert into equity on the company’s next qualifying funding round, or at the end of the loan if they are not repaid. To be eligible, a business must be an unlisted UK
registered company that has previously raised at least £250,000 in equity investment from third party investors in the last five years. We expect more details on eligibility to be released shortly.
The additional £750m managed by Innovate UK is split into three areas with the first payments being made in mid May:
• Acceleration of £200 million to existing Innovate UK recipients
• An extra £550 million will be made available to increase support for existing Innovate UK recipients
• £175,000 of support will be offered to around 1,200 firms not currently in receipt of Innovate UK funding.
Innovate UK provides funding for both SMEs and large businesses engaged in a wide range of R&D activities, which is part of the government’s drive to increase spending on R&D to £22bn by 2024/25.
R&D tax incentives have historically played a large part in funding UK innovation. SMEs are able to obtain an additional deduction of 130% of qualifying spend and are able to claim a tax credit if they are loss making. Large companies can currently claim a credit of 13% of quality spend. Companies remain eligible for these incentives even if their R&D activities are funded by grants, including those received from Innovate UK. However, the claim may be more complex as a result.
United Kingdom
PwC observation:There are a number of complexities associated with both elements of the package; however, it provides a boost to the innovation sector. The key is to make sure your business knows what funding it is eligible for, accesses such funding, and works through the resulting additional complexities in your R&D claim.
Rachael Palmer
London
T: +44 7525 298719E: [email protected]
Katie Attenborough
East Midlands
T: +44 7738 845 125E: [email protected]
Construction projects – Decree 138/020
The Executive Power, in April 2020, issued a Decree to promote construction activities for the sale or lease of property destined to offices, housing and housing developments qualifying as ‘Projects of Great Economic Dimension’.
This measure was originally established by Decree 326/016, and has now been amended by new regulations that grant greater tax benefits and lower requirements related to investment amounts. The scope of construction work and eligible investments is also extended.
The tax benefits include a corporate income tax (CIT) exemption of up to 40% of the eligible investment with an annual exemption limit of 90% of CIT and a 10-year maximum term. As to net wealth tax, there is an exemption for the civil construction work and lands – with different terms depending on the location in or outside the country’s capital. Movable assets are also exempt from this tax during their useful life. In addition, there is a VAT and import taxes exemption, as well as VAT tax credit for the acquisition of equipment, machines, materials and services destined for the civil construction work and for the movable assets designated for common areas. These tax benefits will be applicable for projects submitted as of May 7, 2020.
Uruguay
PwC observation:These provisions are issued with the purpose of promoting new construction projects and would allow the execution of corporate reorganizations with relevant tax and administrative savings.
Patricia Marques
Montevideo, Uruguay
T: +29160463E: [email protected]
Eliana Sartori
Montevideo, Uruguay
T: +29160463E: [email protected]
Carolina Techera
Montevideo, Uruguay
T: +29160463E: [email protected]
Administrative
COVID-19: Australian tax issues and impacts
COVID-19 presents significant challenges to people and organizations around the globe, and the disruption continues to evolve.
Thin capitalization
The COVID-19 crisis is likely to result in the impairment of assets on the balance sheet of many businesses or additional debt or equity raisings, which can raise additional tax implications, including with respect to transfer pricing and thin capitalization.
For thin capitalization purposes, to the extent that a reduction in asset values is reported in financial statements in accordance with accounting standards, this will lead to a reduction in maximum allowable debt calculated using the safe harbour method (broadly 60% of adjusted assets).
The Australian Tax Office (ATO) outlined a simplified approach to the arm’s-length debt test (ALDT) for those that need to rely on it as a direct consequence of COVID-19. The ATO stated that it will not dedicate compliance resources to reviewing the ALDT’s application in the following circumstances:
• The taxpayer would have satisfied the safe-harbour test but for the COVID-19 related balance sheet effects and used its best efforts to apply all of the ALDT’s criteria.
• For entities that are classified as inward investing entities (and not also outward investing entities) no additional related party funding is received, other than short-term (less than 12 months) debt facilities. The ATO expects any new capital to be equity.
• For inward investing entities, the ALDT’s use was not because dividends were paid, thereby weakening the Australian balance sheet.
Foreign investment review
In response to the COVID-19 crisis, temporary changes have been made to the foreign investment review framework which impacts cross-border M&A transactions as well as many internal reorganizations. The Australian Treasurer, the Hon Josh Frydenberg announced that there is now no threshold amount which applies in determining whether a particular foreign investment made on or after 10:30 pm (AEDT) Sunday, March 29, 2020 is subject to Australia’s foreign investment framework. Furthermore, to ensure sufficient time for screening applications, the Australian Foreign Investment Review Board (FIRB) will work with existing and new applicants to extend timeframes for reviewing applications from 30 days to up to six months. These are temporary measures that will remain in place for the duration of the current crisis.
Corporate tax residency & PEs
Global international travel restrictions have resulted in specific tax issues for individuals or businesses needing to relocate their work activities. Of particular relevance is the practical approach taken by the Australian Taxation Office (ATO) in relation to:
• corporate tax residency – if the only reason a foreign company is holding board meetings in Australia or directors are attending board meetings from Australia is because of COVID-19 impacts, then the Commissioner will not apply compliance resources to determine if the entity’s central management and control is in Australia.
• permanent establishments (PE) – if a foreign company did not otherwise have a PE in Australia before COVID-19 impacts, and the presence of the employees in Australia is because they are temporarily relocated or restricted in their travel as a consequence of COVID-19, then the Commissioner will not apply compliance resources to determine if the foreign company has a PE in Australia.
Australia
PwC observation:Affected taxpayers can consider using alternative valuation methods to reduce the impact on their thin capitalization calculations for the current income year. However, many taxpayers may need to consider the arm’s length debt test to maintain their current level of deductions for debt. The ATO also stated that taxpayers should attempt to prepare documents supporting the application of the arm’s length debt test.
Furthermore, foreign investors should now assume that FIRB approval is required for any Australian acquisitions and internal reorganizations. This additional hurdle may cause delays in transactions.
Finally, the ATO’s guidance suggests that COVID-19 impacts should not, by themselves, result in a foreign company’s central management and control being deemed to be in Australia, or a foreign company having an Australian PE.
Peter Collins
Sydney
T: +61 0 438 624 700E: [email protected]
David Earl
Melbourne
T: +61 0 403 416 958E: [email protected]
Jayde Thompson
Melbourne
T: +61 0 403 678 059E: [email protected]
Thin capitalization and valuing debt capital
The ATO issued final Taxation Determination TD 2020/2 which deals with the requirement that an entity complies with accounting standards in calculating the value of its liabilities, which includes its debt capital.
The Commissioner continues to take the view that an entity’s debt capital must be valued in its entirety in the manner required by the accounting standards regardless of whether it comprises debt interests that are classified as financial liabilities, equity instruments or compound financial instruments under the accounting standards.
The Commissioner does not consider that the provisions operate to confine the calculation of value to that part of the debt capital that is classified as a financial liability under the accounting standards. The views expressed in the Determination apply to income years commencing both before and after its issue.
Australia
PwC observation:Taxpayers that have taken the alternative position (i.e., that the value of debt capital for thin capitalization purposes is determined with reference to the financial liability for accounting purposes) should seek advice.
Peter Collins
Sydney
T: +61 0 438 624 700E: [email protected]
David Earl
Melbourne
T: +61 0 403 416 958E: [email protected]
Jayde Thompson
Melbourne
T: +61 0 403 678 059E: [email protected]
Reportable Tax Position reporting changes
The ATO has released 2020 Reportable Tax Position (RTP) instructions which include changes to the definition of a public company, the term ‘foreign-owned company’ and the term ‘majority controlling interest’ have also been defined.
The 2020 RTP Schedule is required to be completed if the company:
• is lodging a company tax return for the year ending 30 June 2020 or later
• is a public company or a foreign-owned company
• has total business income of either:• AUD250 million or more in the current year• AUD25 million or more in the current year
and is part of a public or foreign-owned economic group with total business income of AUD250 million or more in the current year or the immediate prior year.
If the company meets the criteria, it will need to lodge the schedule even if it has no disclosures. Note also that the ATO no longer notifies taxpayers of their obligation to lodge the RTP Schedule.
Australia
PwC observation:Taxpayers should self-assess their obligation to lodge an RTP Schedule in light of the new definitions.
Peter Collins
Sydney
T: +61 0 438 624 700E: [email protected]
David Earl
Melbourne
T: +61 0 403 416 958E: [email protected]
Jayde Thompson
Melbourne
T: +61 0 403 678 059E: [email protected]
Brazil clarifies law on goodwill and step-up deductibility
The Federal Brazilian Tax Authorities (RFB), on March 25, 2020, published Solução de Consulta – Cosit No. 13 / 2020 (dated March 17, 2020) providing that the corporate law definition of ‘control’ should be applied when determining whether parties should be considered ‘dependent’ for the purposes of the rules concerning goodwill and step-up deductibility (SC 13/2020).
Law No. 12,973/2014 amended the legislation surrounding acquisitions and the ability to access deductions related to asset step-up (mais-valia) and goodwill related to future profitability. The legislation specifically included within the conditions for deductibility, the requirement that the relevant acquisition generating the step-up or goodwill must be between ‘non-dependent parties.’ It also included a specific definition, providing that parties will be considered dependent when:
i. The buyer and seller are controlled directly or indirectly by the same party or parties
ii. There exists a relationship of control between the buyer and the seller
iii. The seller is a partner, titleholder, director or administrator of the company making the acquisition
iv. The seller is a relative or similar to the third degree, spouse or partner of the persons listed in item III, or
v. As a result of other relationships not described in items I to IV, in which corporate dependence is proven.
In summary, SC 13/2020 deals with a situation whereby the buyer acquired the shares in a Brazilian company in which the buyer already held an account receivable relating to a previous loan arrangement. Upon the entity’s acquisition, the buyer simultaneously capitalized the loan payable, including interest remuneration until the relevant date. The previous loan agreement contained terms including a guarantee by way of shares in the Brazilian company, as well as creditor approval in relation to certain matters. In light of the above, the taxpayer sought the RFB’s view in relation to the potential application of item II and V (above) to its particular case.
With respect to item II, the RFB considered that although a broader interpretation may be possible, taking into account the context of the rule, the use of the term ‘control’ and its derivatives should follow the corporate law meaning of ‘corporate legal control’ (controle societário), which has also been accepted into the Brazilian tax regulations. As such, in the event that there is no corporate legal control between the buyer and the seller, directly or indirectly, item II should not apply.
In relation to item V, the RFB considered that in the particular circumstances (including creditor approval being required relation to certain matters), it could not be ruled out that the acquisition of the equity interest may set up a relationship of corporate dependence. However, applying a literal interpretation to the relevant legislation, it is necessary to prove (or disprove) the existence of such a relationship based on evidence. The RFB concluded that the assessment of evidence is a task that, as a rule, should be performed during a tax audit/dispute process and not via a Solução de Consulta and therefore found that this part of the taxpayer’s request was invalid.
Brazil
PwC observation:While a Solução de Consulta does not represent law or a legal precedent, it does provide support and guidance for taxpayers in relation to how the RFB is treating such arrangements. The decision highlights the importance of carefully evaluating previous arrangements with potential targets prior to an acquisition taking place in order to minimize the risk of jeopardizing the buyer’s ability to access step-up and goodwill deductions upon acquisition.
Priscila Vergueiro
Sao Paulo
T: +55 11 3674 2115E: [email protected]
Mark Conomy
Sao Paulo
T: +55 11 3674 2519E: [email protected]
Judicial
High Court rules on CFC rules
The High Court of Australia, on March 11, 2020, handed down its decision in BHP Billiton Ltd (now BHP Group Ltd) and Commissioner of Taxation, unanimously dismissing the taxpayer’s appeal.
BHP Billiton Ltd and BHP Billiton Plc are part of a dual-listed company arrangement (DLC Arrangement). BHP Billiton Marketing Ag (BMAG) is a Swiss entity which, during the relevant years, was 58% indirectly owned by Ltd and 42% indirectly owned by Plc. BMAG is the main company conducting BHP’s Singapore marketing business.
The case applied the controlled foreign company (CFC) provisions to the taxpayer with respect to BMAG. Broadly, the Court had to consider whether the taxpayer, a UK based Plc, BMAG and the Australian subsidiaries of Plc were ‘associates’ for tax purposes. The Court found that the relevant group companies were ‘associates’ because there was the requisite level of ‘sufficient influence.’ The ATO also released a statement in response to the High Court’s decision.
Australia
PwC observation:The concept of ‘associate’’ is relevant to many income tax law areas beyond CFCs, including thin capitalization, the debt-equity regime, and withholding tax exemptions. All taxpayers should consider the manner in which their business arrangements are conducted and the extent to which the High Court’s decision potentially could be applied in ascertaining when otherwise independent parties might be taken to have sufficient influence over one another.
Peter Collins
Sydney
T: +61 0 438 624 700E: [email protected]
David Earl
Melbourne
T: +61 0 403 416 958E: [email protected]
Jayde Thompson
Melbourne
T: +61 0 403 678 059E: [email protected]
CRA positions on residency and carrying on business / PEs in Canada during COVID-19
The Canada Revenue Agency (CRA), on May 19, released administrative guidance on certain international tax issues arising from travel restrictions. These administrative positions apply from March 16, 2020 until June 29, 2020 at which time they may be extended or rescinded.
Corporate Residency
Certain Canadian tax treaties contain a residency tie-breaker rule that looks to the corporation’s place of effective management. For corporations covered by such income tax treaties, the CRA’s administrative position is that where a director of a corporation must participate in a board meeting from Canada because of travel restrictions, the CRA will not consider the corporation to become resident in Canada solely for that reason.
Carrying on business in Canada /
Permanent establishment
For non-resident entities in a country with which Canada has a tax treaty, the CRA will not consider a non-resident entity to have a PE in Canada because its employees perform their employment duties in Canada solely as a result of travel restrictions. Similarly, the CRA will not consider an agency PE to have been created for the non-resident entity solely due to a dependent agent concluding contracts in Canada on behalf of the non-resident entity while travel restrictions are in force, provided that such activities are limited to that period and would not have been performed in Canada but for travel restrictions. In addition, for Canadian tax treaties that include a 183-day presence test for a ‘services PE,’ the CRA will exclude any days of physical presence in Canada due solely to travel restrictions.
For non-resident entities in a country with which Canada does not have a tax treaty, if the non-resident entity carries on business in Canada only because of travel restrictions, the CRA will consider whether administrative relief is appropriate on a case-by-case basis.
Canada
Treaties
PwC observation:These administrative positions provide welcome relief to taxpayers who are concerned with potential adverse implications of travel restrictions including creating a PE in Canada or impacting their corporate residency. Where taxpayers intend to rely on this administrative relief, they should maintain documentation to support that the change in behaviour was solely a result of travel restrictions.
Kara Ann Selby
Toronto, Canada
T: +416 869 2372E: [email protected]
Michael C. Black
Toronto, Canada
T: +416 814 5876E: [email protected]
Treasury to interpret references to NAFTA as references to USMCA for certain tax treaty purposes
The IRS and Treasury issued Announcement 2020-06 on May 19, explaining how to interpret references in US income tax treaties to the North American Free Trade Agreement (NAFTA) once it is replaced by the United States-Mexico-Canada Agreement (USMCA). Due to references to NAFTA in certain of the tests for eligibility for treaty benefits – namely, both the ownership and base erosion prongs of the derivative benefits test of the limitation on benefits article of various US tax treaties – a potential technical consideration exists regarding how to interpret references to NAFTA once the USMCA enters into force and replaces NAFTA.
On May 19, the IRS and Treasury announced that upon the USMCA’s entering into effect, for purposes of applying an applicable US income tax treaty, Treasury and the IRS, including the US Competent Authority, believe that any reference to the NAFTA in a US bilateral income tax treaty should be interpreted as a reference to the USMCA. While the announcement resolves the concern when US tax is at issue, it does
not control how treaty partners will interpret the references to NAFTA. The announcement indicates that Treasury and the IRS “will reach out to countries that have an applicable tax treaty containing references to NAFTA to confirm that they agree with this interpretation.”
United States
Oren Penn
United States
T: +202 413 4459E: [email protected]
PwC observation:The announcement provides a helpful resolution, at least where US tax is at issue, to a consideration that otherwise may have led to uncertainty for taxpayers claiming treaty benefits, where they rely upon the derivative benefits test.
Steve Nauheim
United States
T: +202 415 0625E: [email protected]
Eileen Scott
United States
T: +202 445 5283E: [email protected]
Glossary
Acronym Definition
ATAD Anti-Tax Avoidance Directive
ATO Australian Tax Office
BAS business activity statement
BEPS Base Erosion and Profit Shifting
CbCRE Country by Country Reporting Entity
CFC controlled foreign corporation
CIT corporate income tax
CRA Canada Revenue Agency
DAC6 EU Council Directive 2018/822/EU on cross-border tax arrangements
DDT Dividend Distribution Tax
DST digital services tax
DTT double tax treaty
EBITDA Earnings before interest, tax, depreciation and amortization
FIRB Foreign Investment Review Board
Acronym Definition
GST goods and services tax
EU European Union
LOB Limitation on benefits
MFN most favoured nation
MNC Multinational corporation
NAFTA North American Free Trade Agreement
NOL net operating loss
PE permanent establishment
OECD Organisation for Economic Co-operation and Development
R&D Research & Development
RTP reportable tax position
USMCA United States-Mexico-Canada Agreement
VAT value added tax
WHT withholding tax
For your global contact and more information on PwC’s international tax services, please contact:
Bernard Moens Global Leader International Tax Services NetworkT: +1 703 362 7644 E: [email protected]
Geoff JacobiInternational Tax ServicesT: +1 202-262-7652E: [email protected]
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