1.

Global Tax Administration responses for COVID-19:

In view of the gradually evolving situation of COVID-19 outbreak, tax administrations across the
globe have started putting in place measures to support the taxpayers as a whole or a particular class
of taxpayers affected by COVID-19. These taxpayer measures are generally focussed on reducing
compliance burdens for the affected taxpayers and helping them to alleviate cash flow problems. So
far more than 50 countries have taken such measures. A representative account of such measures
has been tabulated below:

S.N Countries Global Tax Administration responses for COVID-19

o.
1. Australia  Deferring by up to four months the payment date of amounts due through the
income tax assessments, fringe benefits tax assessments and excise.
 Allowing businesses on a quarterly reporting cycle to opt into monthly GST
reporting in order to get quicker access to GST refunds they may be entitled to.
 Remitting any interest and penalties, incurred on or after 23 January 2020, that
have been applied to tax liabilities.
2. China  Subsidies and bonuses received by healthcare professionals are exempt from
individual income tax.
 Fully refunding newly increased excess input VAT for producers of important anti-
epidemic materials, one-off deduction in the calculation of enterprise income tax
for equipment that is purchased to enlarge production capacity, and VAT
exemption for incomes derived from the transportation of needed supplies for
epidemic control.
 Full deduction of donations for epidemic control in the calculation of enterprise
income tax and individual income tax.
 Micro, small and medium-sized enterprises nationwide as well as all types of
enterprises in Hubei province of China are exempt from contributions made by
enterprises for their employees' endowment insurance, unemployment insurance
and employment injury insurance for 5 months at most, and large enterprises in
other places of China are eligible for 50% reduction for no more than 3 months.
 From 1st March till end of May, 2020, small-scale taxpayers in Hubei province are
exempt from VAT and the VAT rate outside of Hubei province is reduced from 3%
to 1%.
 The deadline for tax filing in February, 2020 has been extended to the end of March
2020 in Hubei province, and the deadline for tax filing in March 2020 has been
extended nationwide by one week.
3. Japan  Deadline extension (from mid-March to mid-April) for personal income tax, gift tax
and consumption tax return filing and payment.
 Deferral of tax payments for people and businesses negatively impacted by COVID-
19.
4. Singapore  To increase business cash-flow, a CIT Rebate of 25% of tax payable, capped at
$15,000, will be granted for Year of Assessment (“YA”) 2020.
 The carry-back relief scheme for YA2020, qualifying deductions for YA2020 may be
carried back up to 3 immediate preceding YAs, instead of one preceding YA, capped
at $100,000 of qualifying deductions and subject to conditions.
5. France  Employers whose Social Security Contributions due date falls on the 15th of the
month may postpone all or part of the payment of their employee and employer
contributions for the due date of March 15, 2020. The payment date for these
contributions may be postponed for up to 3 months.
 For companies, it is possible to request from the corporate tax department the
postponement without penalty of the payment of their next due dates for direct
taxes.
 Recognition by the State of the coronavirus as a case of "force majeure" for its
 public contracts. Consequently, for all State public contracts, the delay penalties
will not be applied.
6. Italy  Suspension of tax payments for individuals and firms resident in the 11
municipalities of the so-called Red Zone in the period 21 February until 30 April
2020.
 The payment deadline for executive assessment proceedings, tax demands and
resolutions of pending tax disputes is postponed to 31st of May, 2020.
 Tax and Social Security Contributions payments for March and April, as well as VAT
payments for March, are suspended for all firms in the most affected sectors
(tourism, transport, catering, entertainment, education). This suspension also
extends to firms with revenues under 2 million euros.
 Social security contributions due by households for domestic workers are
suspended until 31st May 2020.
 Tax deductions of 30% for charitable donations linked to the COVID19 emergency.
7. Germany  Deferral of VAT, personal and corporate income tax liability for businesses affected
by the virus. Businesses must themselves demonstrate that they have run into
problems due to the corona crisis.
 Default penalties for taxes not paid waived.
8. United  Bespoke Time to Pay arrangements for businesses and self-employed workers who
Kingdom need more time to pay taxes.
 Remove business rates for 2020-21 on property for retail, leisure and hospitality
sectors (up to £51,000 rateable value, subject to state aid limits).
9. Canada  The Canada Revenue Agency (CRA) has developed options to extend the deadline to
file individual income tax and benefit returns several weeks.
 There are also options in development to issue increased refunds for benefit
programs for individuals.
10. USA  The due date for making Federal income tax payments and Federal estimated
income tax payments (including payments of tax on self-employment income) due
on April 15, 2020, in respect of an Affected Taxpayer’s 2019 taxable year and 2020
taxable year respectively, in an aggregate amount up to the Applicable Postponed
Payment Amount, is postponed to July 15, 2020.
 As a result of this postponement, the period beginning on April 15, 2020, and ending
on July 15, 2020, will be disregarded in the calculation of any interest, penalty, or
addition to tax for failure to pay the Federal income taxes postponed by this notice.
 Affected Taxpayers subject to penalties or additions to tax despite the relief granted
by this notice would be able to seek reasonable cause relief for a failure to pay tax or
seek a waiver to a penalty for a failure by an individual or certain trusts and estates
to pay estimated income tax, as applicable.
11. Brazil  Postponement of 3 months of the deadlines for the payment of federal taxes under
the Simples Nacional regime and employer's contribution to the unemployment
severance fund due by legal entities.
 Application of a temporary zero rate for import duty on listed medical supplies
until 30 September 2020 and a special fast track customs clearance procedure for
these products.
12. Colombia  Deadlines for filing tax returns and paying taxes in 2020 have been deferred.
13. Peru  Payment of income tax for individuals and SMEs delayed from late March to late
June 2020.
14. Russia  Tax payment deferral for companies in the tourism and air transportation sectors
(to be extended to other sectors).
 Deferral of social security contributions of up to 3 months for micro businesses (i.e.
enterprises with fewer than 15 employees).
 No tax audits for small businesses, provided that their entrepreneurial activities do
not pose significant risks to the life and health of individuals.

>> Above table can be further downsized or inserted as a .jpg template to optimise space

2. Forum on Tax Administration’s (FTA) response to COVID-19:

 The OECD’s Forum on Tax Administration (FTA) is a forum for co-operation between revenue
bodies of 53 OECD and non-OECD countries created with the aim of promoting dialogue between
tax administrations with the aim of identifying innovative tax administration practices to
increase efficiency, effectiveness and fairness of tax administration and reduce compliance
burdens. The work of FTA is overseen by the FTA Bureau, which comprises heads of revenue
administrations of 13 of the member countries. India is member of the FTA Bureau and the
Revenue Secretary, being head of revenue administration in India, is FTA Commissioner from
India and represents India in the FTA Bureau. In view of COVID-19 situation, number of virtual
meeting of the FTA member countries were held through video conferencing in March, 2020
which were also attended by India. Meetings focussed on - how to ease the burdens of taxpayer
and how business continuity can be maintained within the tax administration to keep the
administration running effectively in these difficult times. During the meeting various countries
shared their COVID-19 responses for taxpayers. FTA is also in the process of creating a
reference document, which will be a live document (to be updated in real time) containing the
tax administration responses to COVID-19 and contact details of international coordinator from
each country.

>>> FTA templates on taxpayer support measures and business continuity plans (attached) can
be inserted to optimise space.

3. Public Consultation on draft Model Rules for Reporting for Platform Operators with
respect to Sellers in the Sharing and Gig Economy

The market of online platforms facilitating the "sharing" and "gig" economies is growing rapidly
and is changing many business sectors. As part of that change, tax administrations are
considering adapting their compliance strategies to reflect that an increasing number of
taxpayers are earning taxable income through such platforms. The growth of sharing and gig
economy platforms presents significant opportunities for tax administrations, as it may bring
activities previously carried out in the informal cash economy onto digital platforms, where
transactions and related payments are recorded in electronic form. At the same time, certain
activities carried out through these platforms may not always be visible to tax administrations
or self reported by taxpayers. This is because the development of the gig economy entails a shift
from traditional work relations under employment contracts to the provision of services by
individuals on an independent basis, which is not typically subject to third-party reporting.
These developments present risks of distorting competition with traditional businesses and
reducing taxable income.  
 
Against that background, a number of tax authorities have already introduced certain reporting
obligations on platform operators to report, while others are planning to introduce similar
measures in the near future. Given, however, that the platforms are facilitating transactions in
the sharing and gig economies on a global scale, there are inherent limitations to the
effectiveness of domestic reporting rules. It is in this light that the OECD has taken forward
work on the development of model reporting rules (the Model Rules) that could be adopted by
interested jurisdictions on a uniform basis to collect information on transactions and income
realised by platform sellers, in order to contain the proliferation of different domestic reporting
requirements and to create efficiencies for tax administrations and platform operators alike.
These draft model rules were published by the OECD for public consultation on 19.02.2020.
Recently, in order to ensure that interested stakeholders have adequate time to give their
comments despite the challenges caused by COVID-19, the OECD has extended the deadline to
submit inputs to 13.04.2020.
4. Ratification of the MLI by Cyprus and Portugal and publication of Synthesised Text of MLI
and India-Belgium DTAA:
India’s treaty partners Cyprus and Portugal have ratified Multilateral Convention to Implement
Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 23.01.2020
and 28.02.2020 respectively. Subsequently, in the month of March, India had prepared draft of
the Synthesised Text of the MLI with these treaty partners and exchanged the same for their
comments. India also published the Synthesised Text of MLI and India-Belgium DTAA during the
month of March, 2020. Synthesized text represents the modifications that are proposed to be
brought in by the MLI in the existing provisions of the DTAA between India and Belgium. The
synthesised text indicates that the MLI will modify the existing DTAA between India and
Belgium in following prominent ways:
 The minimum standard under BEPS Action 6 to tackle treaty abuse i.e., insertion of new
Preamble and the Principal Purposes Test (PPT) shall be achieved.
 The minimum standard under BEPS Action 14 relating to the Mutual Agreement
Procedure shall get implemented.
 Artificial avoidance of Permanent Establishment (PE) status through commissionaire
arrangements and deliberate fragmentation of activities & claiming them under specific
activity exemptions would be prevented.
 Provisions related to “Corresponding adjustment” to avoid economic double taxation
will be inserted.
 Taxing rights related to capital gains from alienation of shares/ interests deriving value
principally from immovable property has been widened to include interests in
partnership firms and trusts.
So far India has published Synthesised Text of the MLI with 17 tax treaty partners. These
Synthesised Texts have been published on the official website of the Income Tax Department
and the same can be accessed at https://www.incometaxindia.gov.in/Pages/international-
taxation/dtaa.aspx.

5. Notification of Tax Information Exchange Agreement (TIEA) between India and Brunei
Darussalam:
On 04.03.2020, India notified the India-Brunei Darussalam TIEA in the official gazette. This
Agreement was signed on 28.02.2019 and the same has entered into effect on 30.01.2020. This
Agreement will help in facilitating the exchange of information between the two countries
including sharing of information held by the banks and other financial institutions
encompassing the information regarding the legal and beneficial ownership. It will also facilitate
the assistance in collection of the tax claims between the two countries.

>> Amrita can add some other points, if required, as this TIEA pertains to her division.
6. Virtual meeting of OECD’s Working Party-11 on Pillar two of work related to addressing
tax challenges of digital economy:

>>> Write-up to be provided by Pooja.

7. Virtual meeting of Forum on Tax Administration (FTA) Bureau:

>> This will be updated once meeting happens. Meeting is scheduled on 26.03.2020.