Staying Up-To-Date with COVID-19 Stimulus Responses
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EY Tax Controversy Covid-19 Response Tracker 2 April 2020 Important notes ► Governments around the world are actively taking steps to protect their economies from the economic damage being caused by the Covid-19 virus. Whether through tax cuts, investment incentives or changes to filing deadlines, tax will play a significant part in helping alleviate the financial and economic turmoil that is now occurring ► Tax Administration measures and changes across the globe are being proposed and implemented daily, making it more important than ever for businesses to stay abreast of developments ► This document provides a snapshot of the Tax Administration changes that have been announced in jurisdictions around the world in response to the Covid-19 crisis. It is designed to support conversations about measures that have been proposed or implemented in key jurisdictions ► This document is updated on an ongoing basis but not all entries will be up-to-date as the process moves forward. In addition, not all jurisdictions are reflected in this document ► Please consult with your EY engagement team to check for new developments ► EY has developed additional trackers to help you follow changes: ► Tax Policy ► Labor and Employment Law ► Immigration Policy ► EY Tax professionals are updating the trackers regularly as the situation continues to develop Page 2 EY Tax Controversy Covid-19 Response Tracker Jurisdictions covered Algeria Australia Belgium Bulgaria Canada Chile Colombia CostaRica Cyprus Czech Republic Denmark Ecuador El Salvador Finland France Germany Greece Guatemala Honduras Hong Kong Hungary Indonesia Ireland Israel Italy Japan Latvia Lithuania Luxembourg Mainland China Malaysia Mexico The Netherlands New Zealand Panamá Peru Philippines Poland Portugal Puerto Rico Qatar Romania Russia Singapore Slovakia Spain Sweden Taiwan Thailand Turkey Ukraine United Kingdom United States Venezuela Vietnam Page 3 EY Tax Controversy Covid-19 Response Tracker • Contact: Contact: Imene Henni Algeria • Contact: Bruno Messerschmitt • Last updated: 19 March 2020 Category: Tax Controversy Back to top Tax audits Tax collection Tax litigation ► Monthly tax returns, submissions and payments due in February are postponed until 20 April 2020 for taxes, such as the Tax on Professional Activity (TAP), Corporate Income Tax installments, Personal Income Tax (PIT) and Value-Added Tax (VAT ); the postponement applies only to taxpayers registered with the regional tax inspections centers ► Taxpayers registered at Direction des Grandes Enterprises (DGE) are not eligible for this postponement as they submit their tax returns on an electronic platform (Jibayatic) Page 4 EY Tax Controversy Covid-19 Response Tracker • Contact: Martin Caplice Australia • Last updated: 24 March 2020 Category: Tax Controversy Back to top Tax audits Tax collection Tax collection Tax litigation ► Audit activity is Decreasing tax payment obligations and deferring Supporting Employees/Contractors ► For the Federal Court ongoing, but tax debts ► Employers are to ensure that employees of Australia it is subject to ► The ATO has announced a process for reducing tax are able to access all available relief to business as usual extensions of payment obligations by varying PAYG instalments minimise the consequences of industry ► Court hearings are to time upon for March 2020 to reflect the estimated taxable being shut down, they should consider: be conducted by taxpayer request income for the year ► Whether termination is preferable to video link through ► The Second ► Payment deferrals to help manage cash (e.g., a unpaid leave to enable access to the use of the Commissioner potential deferral of up to 6 months for BAS government benefits “Microsoft Teams” directed the software with judges payment obligations including PAYG and GST) ► Whether any payments can be Australian Tax and attorneys ► In relation to GST, businesses on a quarterly structured as termination payments Office (ATO) reporting cycle may elect to change their GST (not for beneficial tax treatment appearing remotely staff to be PAYG) reporting to monthly cycles starting 1 April Ancillary matters ► For the flexible in 2020 to get quicker access to GST refunds Administrative relation to any ► Instant asset write off: Companies with an Appeals Tribunal ► Remission of interest and penalties for late extension of time aggregated annual turnover of under (AAT), all payment will be available on a case by case basis requests $500 million will be eligible for an interlocutory ► Companies are still required to meet their instance asset write off of $150,000, per proceedings are to be superannuation obligations as there is no power to eligible asset conducted by change the contribution due date or waive the ► Acceleration of depreciation: A 15 month telephone super guarantee charge time limited investment incentive is being ► The AAT procedure ► Fringe Benefit Tax exemptions are available for introduced that will provide for for final hearings is benefits provided as a result of COVID-19 (e.g., accelerated depreciation for new assets undergoing review because of illness or returning an employee home) ready for use by 30 June 2021 Page 5 EY Tax Controversy Covid-19 Response Tracker • Contact: Steve Claes — Tax Controversy Belgium • Last updated: 19 March 2020 Category: Tax Controversy Back to top Tax audits Tax collection Tax litigation ► Payment plans, waivers of late payment interest and waivers of penalties for non- payment are available at taxpayer request if certain conditions are met Page 6 EY Tax Controversy Covid-19 Response Tracker • Contact: Milen Raikov — Tax Controversy Bulgaria • Last updated: 19 March 2020 Category: Tax Controversy Back to top Tax audits Tax collection Tax litigation ► The deadline for annual CIT returns is extended until 30 June 2020 ► The deadline for payment of local taxes and fees with a discount is extended Page 7 EY Tax Controversy Covid-19 Response Tracker • Contact: Paul Mulvihill Canada • Last updated: 18 March 2020 Category: Tax Controversy Back to top Tax audits Tax collection Tax litigation ► Suspension of audit interaction — For most ► The CRA has announced that collections ► Any objections related to Canadian businesses, the Canada Revenue Agency activities on new debts will be suspended taxpayers’ entitlement to benefits and credits (CRA) will temporarily suspend audit until further notice and flexible payment have been identified by the CRA as a critical interaction with taxpayers and their arrangements will be available service which will continue to be delivered representatives during this time. With respect to objections related to other tax matters filed by ► GST/HST: Hold on initiation of audits for small and medium-sized businesses. The CRA individuals and businesses, the CRA is will not contact any small or medium-sized currently holding these accounts in abeyance businesses over the next four weeks to ► On 16 March 2020, the Tax Court of Canada initiate any post-assessment GST/HST audit ordered the extension of all timelines prescribed by the rules of that Court while it ► Income Tax: Hold on initiation of audits for small and medium-sized businesses - the CRA is closed for business until 30 March 2020 will not contact any small or medium-sized businesses over the next four weeks to initiate any post-assessment income tax audit Page 8 EY Tax Controversy Covid-19 Response Tracker • Contact: Carlos Martínez Chile • Last updated: 18 March 2020 Category: Tax Controversy Back to top Tax audits Tax collection Tax litigation ► The Chilean tax authority has launched new online tools on its website to obtain tax ► Relief measures for tax IDs and to improve management of monthly taxes debts that are intended to provide incentives to ► On 18 March, the Treasury Ministry announced an economic incentive package mainly focused on funds to support small/medium business in the amount of USD $11,750 small/medium million, or equivalent to 4.7% of the Chilean GDP. Key components are sanitary businesses and systems, family revenues and employment protections individual taxpayers with low incomes to enter into ► The following tax measures are included: tax debt payment ► Corporate tax Monthly Provisional Payments (MPP) are suspended for the next agreements three months ► Deferral of VAT payments for the next three months for Chilean entities with revenues lower than USD $11.7 million with the possibility to pay the owed VAT in 12 monthly installments without additional interest ► Deferral of Real Estate Tax returns (to be paid in April) due during 2020 without additional interest for the delay. This benefit is applicable to Chilean entities with revenues lower than USD $11.7 million and individuals that own real estate properties assessed for tax purposes in an amount lower than USD $156,000 ► Small and medium business may defer income tax returns until July 2020 ► A transitory exemption of the Stamp tax (applicable to credit cash operations) for the next six months ► Deductibility of all expenses incurred by Chilean company for sanitary purposes Page 9 EY Tax Controversy Covid-19 Response Tracker • Contact: Margarita Salas Colombia • Last updated: 18 March 2020 Category: Tax Controversy Back to top Tax audits Tax collection Tax litigation ► The ordinary terms of tax authorities’ ► The income tax payment deadline has been ► All litigation proceedings are suspended until activities have been suspended until 6 April extended by one week 13 April ► Face-to-face meetings have been suspended; ► Some municipalities