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Japan: New Japanese invoicing requirements for consumption tax (JCT)

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The Japanese value added tax is referred to as JCT. As all taxes around the world have connections with the history of the tax mechanism of each country, the explanation below also covers the history of the discussions regarding introducing value added tax in Japan.

Argentina: Resolution No. 4930/2021. Regulation of Contribution of Great Fortunes

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Federal Tax Authority (FTA) General Resolution No. 4930/2021 ("Resolution") was published in the Official Gazette on 8 February 2021, regulating the procedure to assess and pay the Solidarity and Extraordinary Contribution to Help Mitigate the Effects of the Pandemic created by Law No. 27,605 ("Contribution"), as well as certain clarifications related to information regimes related to the Contribution.

Ukraine: Mandatory registration of non-residents with the tax authorities by 31 March 2021

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Foreign entities operating in the territory of Ukraine, including those who already have a representative office in Ukraine, must register with the tax authorities by 31 March 2021.

Sweden: New ruling – VAT liability for co-location services

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Overruling earlier precedent, the Swedish Supreme Administrative Court decided, in a ruling from 4 February 2021, that the supply of connectivity, capacity and space in a data center should not be exempt from VAT liability as letting of immovable property. The ruling aligns Swedish law with the reasoning of the European Court of Justice (CJEU) in the recent A Oy case and is positive news for the Swedish co-location and data center industry.

Latin America Energy, Mining & Infrastructure Hot Topics Guides 2021

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As the energy, mining and infrastructure industry in Latin America looks ahead to the new year, we present the Latin America EMI Hot Topics...

Luxembourg: Interest deduction limitation rule – New guidance released by the Luxembourg tax authorities

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In brief On 8 January 2021, the Luxembourg tax authorities released Circular L.I.R. No. 168bis/1 ("Circular") providing guidance on the application of the interest deduction...

Luxembourg: Law on the denial of deductibility of interest and royalty payments made to...

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On 28 January 2021, the Luxembourg Parliament (Chambre des Députés) adopted1 bill of law 7547 on the non-deductibility of interest and royalty payments made to related parties in non-cooperative jurisdictions (“Law”).As explained in our tax alert dated 20 April 2020, the new provision amends Article 168 of the Luxembourg Income Tax Law (LITL), which lists non-deductible expenses for taxpayers subject to corporate income tax. The Law therefore completes the scope of non-deductible expenses by adding a rule of non-deductibility of interest or royalty expenses paid by a Luxembourg taxpayer to a related company established in a country or territory appearing on the list of the EU as a non-cooperative tax jurisdiction.

Latin America Energy, Mining & Infrastructure Hot Topics Guides 2021

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As the energy, mining and infrastructure industry in Latin America looks ahead to the new year, we present the Latin America EMI Hot Topics...

Malaysia: Penalty for failure to furnish transfer pricing documentation

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The Malaysian Finance Act 2020 introduced, among others, several legislative changes to the Malaysian Income Tax Act 1967 (ITA) in respect of transfer pricing. Notably, a penalty provision was introduced. Effective 1 January 2021, taxpayers (where applicable) who fail to furnish transfer pricing documentation (TPD) upon the Malaysian Inland Revenue Board's (MIRB's) request will be subject to a fine ranging from RM 20,000 to RM 100,000 and / or imprisonment.Consistent with this, the MIRB has also revised the Transfer Pricing Guidelines 2012 to reduce the time given to taxpayers to furnish their TPD from 30 days to 14 days.

United States: Treasury and the IRS release long-anticipated Section 45Q final regulations

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On January 6, 2021, Treasury and the Internal Revenue Service (IRS) issued final regulations (“Final Regulations”) relating to the credit for carbon oxide capture and sequestration under Code Section 45Q.  These regulations finalize proposed regulations issued in May 2020 (“Proposed Regulations”).  Congress enacted section 45Q in 2008 to incentivize the capture and disposal of carbon dioxide to prevent release into the atmosphere.  Originally, the credit was available for carbon dioxide that was captured and either disposed of in secure geological storage or injected into an enhanced oil recovery (“EOR”) project.  However, in 2018 Congress expanded the credit to also cover carbon monoxide and to cover additional methods to “utilize” captured carbon oxide.
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