COVID-19 Coronavirus

The Australian Taxation Office has amended its guidance on the rules regarding the creation of a permanent establishment in Australia in response to the COVID-19 pandemic.

The American Rescue Plan Act enacted on March 11 provides over $195 billion in direct aid to states but includes a provision prohibiting the use of those funds to “either directly or indirectly offset a reduction in the net tax revenue” of a receiving state. Businesses should monitor tax measures potentially impacted by this provision and the status of Treasury guidance on the issue.

Acknowledging that the COVID-19 pandemic continues to present challenges for taxpayers, the IRS has announced that it is automatically extending the individual income tax filing and payment deadline for the 2020 tax year from April 15 to May 17. The agency said that it will be providing formal guidance in the next few days.

Japan’s National Tax Agency (NTA) has announced that the deadline to pay tax and file 2020 individual income tax returns, individual consumption tax returns and gift tax returns with a 15 March 2021 deadline will be extended to 15 April 2021, in light of issues created by COVID-19.

This edition of Tax Tips provides a recap of the New Zealand Government's COVID-19 support measures and also discusses the NZ Inland Revenue's new exposure draft on the administration of the imported hybrid mismatch rule, which sets out the steps Inland Revenue expects taxpayers to have undertaken before claiming deductions for cross-border related party payments.

The Indian government has issued the much-awaited circular for individuals who were on a visit to India and then stranded due to COVID-19 travel restrictions. After referring to the applicability of treaty provisions, OECD commentary and some of the positions taken by other countries in dealing with a similar situation, the Indian government concluded that in the majority of cases these individuals will not trigger double taxation or get the relief from double taxation under the relevant treaty.

The Senate on March 6 passed by a vote of 50 to 49 a Senate substitute amendment to the COVID relief legislation that made certain changes to the House-passed budget reconciliation bill (H.R. 1319, the American Rescue Plan Act of 2021). The final vote came Saturday afternoon after an all-night session in which a number of additional amendments were considered.

COVID-19 vaccinations have been taking place for a few weeks in Germany. For assigned employees, the question arises under which conditions and in which country they are entitled to the vaccination.

US State and local budget processes were significantly disrupted by the impact of COVID-19. States and localities now confront difficult tax and budget choices in the current and upcoming legislative sessions.

The US Senate this week is expected to begin consideration of the $1.9 trillion ‘American Rescue Plan Act’ that was approved by a House vote of 219 to 212 in the early hours of February 27. The House-passed legislation includes tax relief and tax increase provisions that are estimated by the Joint Committee on Taxation (JCT) staff to reduce overall federal revenues by $590.7 billion over 10 years.

The House Ways and Means Committee recently advanced legislation to implement budget reconciliation instructions regarding COVID-19 relief. The budget resolution passed by Congress included reconciliation instructions for 12 House committees to draft legislation to implement President Joe Biden’s proposed $1.9 trillion COVID-19 relief plan.

A summary of the pan-European measures in place to assist commercial tenancies during the COVID-19 pandemic, as well as an overview of the back to work provisions being introduced.

The House and Senate have passed budget resolutions that are the first step in advancing COVID-19 relief under the reconciliation process that requires only a simple majority vote for passage. The budget resolutions include reconciliation instructions for committees to draft legislation to implement President Joe Biden’s proposed $1.9 trillion COVID-19 relief plan for individuals, businesses, and communities that would build on the $900 billion COVID relief package enacted in December.

Over the past few weeks we have seen a marked increase in HMRC audit activity regarding the 'Eat Out to Help Out' (EOTHO) scheme. HMRC had initially anticipated that the scheme would cost approximately £500m, but the eventual claim figure was £840m. HMRC has now started an information gathering and review process and has initially contacted 4,000 claimants, with selected businesses being required to attend a virtual meeting and/or telephone interview as a first step.

As the COVID-19 situation continues to evolve globally, support measures introduced previously by the Inland Revenue Authority of Singapore (IRAS) and the Central Provident Fund (CPF) Board have been progressively updated to ensure targeted assistance to Singaporeans and businesses affected by the COVID-19 developments.

The OECD has published Updated guidance on tax treaties and the impact of the COVID-19 pandemic that deals with:

A year has passed since the first COVID-19 lockdown in the United Kingdom (UK) and lockdowns are still in force in many parts of the world. Since then, employers have been dealing with displaced workers globally – some of which may still now be stranded in an unexpected location. Both the UK tax authorities (HMRC) and the OECD have recently published additional guidance on the taxation of temporary displaced employees in response to concerns on the tax impact of COVID-19.

Taxpayers conducting business in the City of Los Angeles, as well as in neighboring cities, may be subject to the annual Los Angeles City Business Tax (LACBT) with a filing deadline of March 1. As a result of the COVID-19 pandemic, with many employees working remotely, taxpayers unexpectedly may find themselves triggering a filing obligation or increasing/decreasing their level of business activity in Los Angeles. For companies subject to the tax but not yet registered, a voluntary disclosure program is available.

California Governor Gavin Newsom (D) advanced his fiscal year 2021-22 proposed budget to the legislature on January 8. The budget provides for expansion of existing business incentive and tax relief programs and introduces new initiatives to support and expedite California’s economic recovery in the wake of the economic dislocation brought about by COVID-19. Governor Newsom’s proposed budget includes increased funding for the California Competes Tax Credit (CCTC) in both fiscal years 2020-21 and 2021-22. The proposed budget also establishes a grant component of the California Competes program to expand the pool of businesses that can benefit from the program.

President-elect Joe Biden has proposed a $1.9 trillion emergency legislative package (the American Rescue Plan) to fund COVID-19 vaccinations, provide increased direct relief to individuals, and support communities. Biden said the proposal is the first step in a two-part plan that is needed immediately and will be followed by an economic recovery plan -- the Build Back Better Recovery Plan -- that he will outline in February.

To mitigate some of the challenges presented by ongoing travel restrictions, the Hong Kong Immigration Department (‘ImmD’) has announced that it will start accepting visa extension applications for certain non-permanent residents from outside of Hong Kong, who as a result of COVID-19 have not been able to return to Hong Kong to submit their applications in a timely manner.

The Organisation for Economic Co-operation and Development (OECD) recently issued Guidance on transfer pricing implications of the COVID-19 pandemic as part of its efforts to provide policy recommendations to respond to the COVID-19 pandemic.

The US Congress recently approved a $2.4 trillion legislative package to fund the federal government through the end of the fiscal year, provide further COVID-19 economic relief, and extend certain expiring tax provisions. Additional measures include provisions to eliminate ‘surprise’ medical billing. The House passed the legislation by a vote of 359 to 53 and the Senate voted 92 to 6 to clear the legislation for President Trump’s expected signature.

On 11 December 2020, the Australian Taxation Office (ATO) provided new guidance in relation to the employer obligations for foreign employers with respect to employees working remotely from Australia who normally reside in another country.

The 2017 tax reform act generally eliminated the deduction for business expenses for providing employees with qualified transportation fringe benefits and for providing or paying for employee commuting. The IRS and Treasury have finalized regulations proposed in June 2020 on these disallowances. The final regulations provide helpful clarifications, especially as regards the application of the exceptions for QTFs to the disallowance and how the rules apply during the COVID-19 pandemic.

Where a business has a filing deadline which it is unable to meet due to the impact of COVID-19, we recommend it proactively contacts HMRC to discuss their circumstances, as it may be possible to agree a deferral of the issue of late filing penalties. HMRC has recently set out its policy for agreeing such a deferral of late filing penalties for a corporate interest restriction (CIR) returns.

Many businesses will be aware that, due to the impact of the coronavirus (COVID-19) pandemic, Companies House provided companies with a 3-month filing extension by virtue of the "Corporate Insolvency and Governance Act 2020" and "Companies etc. (Filing Requirements) (Temporary Modifications) Regulations 2020". Despite this extension, there is currently no formal process for obtaining an extension from HMRC to the statutory filing deadline for corporation tax returns.

In this recently published Bloomberg article, Will Morris, PwC’s Deputy Global Tax Policy Leader discusses tax trends in the wake of COVID (including international efforts to review the taxation of digital businesses) and considers what governments, international organisations and businesses should keep in mind to achieve beneficial solutions for everyone in the post-COVID world.

On the 10 November additional guidance on the extension of the Coronavirus Job Retention Scheme (CJRS) was released and hopefully this will mean we now have some certainty and no further significant amendments.

The Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular (RMC) No. 83-2020 to address the issues and concerns of taxpayers who were stranded in the Philippines due to COVID-19.

On 5 November the Chancellor announced that the extension to the Coronavirus Job Retention Scheme (CJRS) will run until 31 March 2021. Under the extension, employees will receive 80% of their usual salary for hours not worked, up to a maximum of £2,500 per month. The Government also confirmed there will be a review of the policy in January, to decide whether economic circumstances are improving enough to ask employers to contribute more. In the meantime the Job Support Scheme has been postponed.

In June this year, the Disaster Management Tax Relief Bill, 2020, and the Disaster Management Tax Relief Administration Bill, 2020 (‘the COVID-19 tax relief Bills’), were introduced in Parliament in order to give effect to tax proposals and aimed at addressing the fiscal and economic effects of COVID-19 in South Africa. On 13 October 2020, the National Treasury and the South African Revenue Service presented a Draft Response Document on the 2020 Draft Taxation Laws Amendment Bill.

The Malaysian Inland Revenue Board (MIRB) published an updated Frequently Asked Questions document (FAQ) on its website on 19 October, 2020 regarding companies and individuals who have been impacted by COVID-19 travel restrictions. Future updates to the FAQ by the MIRB may be posted to the same URL.

Over the weekend, we saw a significant amount of change in relation to the Government's Coronavirus support package for employers and employees. Initially, the Job Support Scheme (JSS) was due to be launched on Sunday 1 November, but has now been postponed due to the forthcoming lockdown in England (from 5 November until at least 2 December). As a result, the Prime Minister announced an extension of the Coronavirus Job Retention Scheme (CJRS), for the “month of November” but with some important changes to the original CJRS scheme. The availability of support under this extended scheme is welcome news for affected employers.

The COVID-19 pandemic has strained and depleted the finances of state and local economies around the country. New Jersey is no exception. Citing deep revenue shortfalls, largely attributable to the pandemic, Governor Phil Murphy signed the Fiscal Year 2021 state budget into law September 29. The budget legislation adopts several changes to the personal and corporate income tax laws designed to help raise revenue.

Please join us for this latest Tax Function of the Future webcast on Tuesday, October 20th at 7pm.

The social security authorities of Germany, Switzerland and Austria have agreed on flexible arrangements for individuals who have an ordinary job in several European Union and EEA countries as well as in Switzerland (i.e. multi state employees) until 31 December, 2020 due to a temporarily different distribution of working time between the individual countries.

In April, the IRS provided a maximum 60-day period to generally exempt foreign persons from being treated as engaged in a US trade or business (USTB) and/or from having a US permanent establishment (PE) to the extent such foreign person’s presence in the United States was deemed to be caused by the COVID-19 pandemic. While many employees continue to work remotely in different jurisdictions, whether by choice or due to the pandemic, the US Treasury Department and the IRS have not extended the relief period. As a result, companies may be risking USTB or PE exposure and inadvertently establishing a taxable presence in the United States.

n April 2020, Her Majesty's Revenue and Customs (HMRC) issued guidance to employers about social security withholding obligations in the event employees temporarily returned to work in the UK from the EU, EEA or Switzerland. They now have followed this up with guidance on cases where employees returned to the UK from a country where the UK does not have a social security agreement.

The US CARES Act established the Paycheck Protection Program (PPP) which allows qualifying small businesses (eligible recipients) to obtain loans guaranteed by the Small Business Administration (SBA). The IRS has issued Announcement 2020-12, notifying lenders of covered loans made under the PPP that they should not file information returns or furnish payee statements under Section 6050P to report the amount of qualifying forgiveness with respect to those loans.

In our seventh edition of trends in tax transparency, we look at how tax is becoming a key sustainability issue for many organisations. We're seeing an increased interest from Environmental, Social and Governance (ESG) investors in the tax affairs of businesses and anticipate the level of scrutiny will only intensify, as a consequence of COVID-19.

In response to the COVID-19 pandemic, many US states have declared states of emergency and imposed temporary social-distancing measures and other restrictions. Many businesses, in turn, have implemented work-from-home requirements for their employees. However, what may be a surprise is that these changes may have significant unexpected state tax implications and could create potential tax risk for both individuals and their employers.

There is now extensive, although still fragmented and not fully perfectly aligned (if not outright contradictory), guidance on COVID-19 related Transfer Pricing (TP) issues coming from a number of sources.

We have confirmed with HMRC that SAO filing deadlines have been revised to align with the recent Companies House accounts filing extensions. At its simplest, a limited company with a 31 December 2019 year end for instance, would normally have to file its accounts with Companies House, and its SAO certification with HMRC, by 30 September 2020. The new rules provide for a three-month extension in this situation, moving both filing dates to 31 December 2020.

HMRC has provided guidance on the R&D credits treatment of staffing costs for furloughed employees. HMRC's updated guidance provides that, as furloughed employees will have needed to cease all work for their employer, they cannot have been directly and actively involved in the R&D activity when furloughed, and therefore the costs of these employees will not qualify for R&D credits for any furlough period.

Businesses are grappling with the evolving day-to-day challenges of COVID-19, but many have proven remarkably resilient and adaptable, staying open by switching to virtual working. Some companies have experienced unanticipated benefits of this model and now are considering extending virtual working even as restrictions are lifted.

Modern slavery and its often hidden place in society is receiving notable front page media attention. Alongside this, corporate respect for human rights is becoming a priority consideration for commercial stakeholders and the public, and the reputational and financial damage for companies failing to uphold strong human rights standards have seen modern slavery compliance jump up the board room agenda. Simultaneously, the impact of COVID-19 has created unprecedented pressure on working practices and supply chain relationships, particularly with regard to workforce vulnerability. This article explores how businesses can turn this potential reputational risk into reputational opportunity.

On 9 July 2020, HM Revenue and Customs (“HMRC”) announced that it had made its first arrest  for fraud  relating to the coronavirus job retention scheme (“CJRS”).

 

Congress and the IRS continue to provide relief to alleviate hardships caused by the ongoing COVID-19 pandemic.

The High Court’s decision in Re A Company (Application to restrain presentation of petition) [2020] EWHC 1406 (Ch) has indicated that the Corporate Insolvency and Government Bill, despite not yet being in force at the time of the application (the Bill has since been granted Royal Assent on 25 June 2020), is to be treated as though it is active legislation in relation to winding up petitions, in anticipation of the legislation obtaining royal assent. It is apparent that the Court has used its right to take into account even the possibility of a change in the law, in order to make clear that creditors have little to gain from presenting COVID-19 related winding up petitions in advance of the Bill coming into force.

The European Commission has proposed a detailed COVID-19 Recovery Plan which includes more taxes going directly to the European Union. In the short term, the European Union will borrow to finance Member State investment in what is effectively the multi-annual financial framework (MFF) for 2021-2027. The framework will be discussed in the coming months and, if approved, put in place this year.

The Governor of Puerto Rico recently signed House Bill No. 2468 into law as Act No. 57-2020, which provides additional economic and tax relief measures to address the effects of the COVID-19 pandemic.

A summary of the pan-European measures in place to assist commercial tenancies during the COVID-19 pandemic, as well as an overview of the back to work provisions being introduced.

Watch the replay of this US webcast held on Friday, 19 June 2020.

Taxpayers generally must deduct a loss under Section 165 in the tax year the loss occurs, but under Section 165(i) may elect to deduct a loss attributable to a federally declared disaster in the preceding tax year. In response to the COVID-19 pandemic, the President has issued a federal disaster declaration for all 50 states. Accordingly, taxpayers may elect to claim otherwise deductible losses sustained in 2020 and attributable to the pandemic on their 2019 tax returns. What constitutes a loss attributable to a disaster that qualifies for treatment under Section 165(i) depends on a taxpayer’s particular facts and circumstances.

The COVID-19 pandemic has elicited a very different response when compared to previous financial crises. For example, governments cannot lean on policies that might increase demand, the standard fiscal stimulus for a regular economic downturn. Many governments are adjusting VAT/GST systems as a rapid response measure to assist with financial liquidity. In this Bulletin, we look at three specific areas.

In this month’s edition, we present the following articles: Senior Accounting Officer: do you have a deadline on the horizon? Corporate governance response to COVID-19 and its future The benefits of real time R&D claims Operational Resilience: How to deliver on your tax needs and remain resilient Update on non-resident capital gains tax HMRC Time to Pay (TTP) Update

In a post-COVID-19 Australia, the opportunity for tax reform has never been greater. As the country looks to generate revenue to support ongoing government relief measures, now is the time to begin planning for comprehensive changes to the system.

On 3 June 2020, the committee of the German coalition government agreed a €130 billion fiscal stimulus package to mitigate the economic damage created by the coronavirus pandemic. With almost 60 cross-sector measures announced, these latest measures represent the largest economic stimulus package in the history of the Federal Republic of Germany.

Alongside public health and economic measures, governments have been activating in-country tax relief measures to reduce or delay taxpayers’ tax liabilities and administrative burdens as a result of the COVID-19 pandemic. Tax authorities have been providing guidance and taxpayers have been deciding, where relief measures are not automatically applied, whether and how to avail themselves of such measures in appropriate situations.

The IRS recently posted to its Coronavirus Tax Relief and Economic Impact Payments website frequently asked questions (FAQs) providing guidance for C corporations planning to file Form 1120X, Amended U.S. Corporation Income Tax Return, or Form 1139, Corporation Application for Tentative Refund, on or after June 1, 2020, to carry back net operating losses (NOLs) to years in which the alternative minimum tax (AMT) applies.

A summary of the pan-European measures in place to assist commercial tenancies during the COVID-19 pandemic, as well as an overview of the back to work provisions being introduced.

The House recently voted 208 to 199 to pass a $3 trillion ‘Phase Four’ COVID-19 relief bill that would provide additional economic assistance to individuals and businesses. While the Congressional Budget Office has not yet released an estimate of the budgetary cost of the entire legislation, the House Democratic bill includes nearly $1 trillion for state and local governments that have been impacted by the economic effects of the pandemic and over $1 trillion in tax reductions, partly offset by tax increases.

The IRS recently issued Revenue Procedure 2020-30, providing guidance with respect to certain foreign branch issues raised by the COVID-19 pandemic. Rev. Proc. 2020-30 excludes certain ‘temporary activities’ from (1) resulting in an obligation to file a Form 8858 and (2) giving rise to a foreign branch separate unit for purposes of the Section 1503(d) dual consolidated loss (DCL) rules.

Read our EUDTG Newsalert on the European Commission's proposals to defer the deadlines under DAC2/DAC6 due to COVID-19.

The first annual work programme of the new European Commission was published in January. The COVID-19 crisis has led to a general reassessment of the program, but the Commission is not expected to delay its most important tax-related projects. Initiatives on ‘Fighting tax evasion’ and ‘Business taxation for the 21st century’ are strategic priorities.

According to PwC’s Global Economic Crime Survey 2020, over half of UK businesses reported an incident of fraud, corruption or other economic crime in the last two years. This is the highest rate recorded in the Survey and indicates an upward trend in sophisticated fraud. Should the impact of COVID-19 align with previous unprecedented events (for example the 2008 financial crisis) we can expect to see an increase in financial crime as fraudsters look to exploit areas of weakness. In this article we look at the types of financial crime that may arise during the COVID-19 pandemic and what businesses can do to minimise risk and protect itself accordingly.

As businesses continue to grapple with the economic implications of the COVID-19 pandemic, the New Zealand Government has enacted urgent legislation to provide further economic support through a number of tax changes contained in the COVID-19 Response (Taxation and Other Regulatory Urgent Measures) Act 2020 (the Act). The Act gives effect to a number of tax changes which were previously announced by the Government on 15 April.

Please join us on Tuesday, May 5, 2020 at 7PM for this latest webcast.

An individual’s personal residence position for UK tax purposes in a given tax year is generally determined by a combination of the number of days they spend in the UK and their links with the UK. A key tax risk area that individuals are facing due to the current global COVID-19 pandemic is that international travel has been heavily restricted and individuals could end up spending longer in the UK than they had anticipated. Visitors are therefore at risk of becoming unexpectedly UK tax resident, and hence taxable in the UK, through no fault of their own and without having made appropriate plans ahead of time.

Watch this webcast replay from Wednesday, 29 April 2020, where PwC leaders Tim Ryan, Amity Millhiser and Bhushan Sethi had a conversation about the corporate response to the health and economic crisis.

If you missed this webcast on Tuesday, 28 April 2020, you can watch the replay here.

On 20 April, HM Treasury launched a billion-pound support package for innovative firms impacted by Coronavirus. Whether companies are investing in new R&D projects or focused on just surviving in the current climate, this new package is aimed at ensuring Britain remains a global leader in innovation, now and in the future. Our Innovation & Capital Incentives team supports SMEs and large businesses claiming R&D tax incentives, helping them ensure their claims are optimised. The key thing is making sure that your business knows what funding it is eligible for and accessing it.

Often a company’s tax position will be heavily linked to where it is managed from and where its employees are located. This can drive both the tax residence of the company as well as the question of whether it has a taxable permanent establishment in a second territory. With global travel at a virtual standstill, and typical ways of working massively disrupted, the current environment has the potential to create significant risks in this area.

A package of emergency fiscal measures to mitigate the economic impact of Covid-19 (“Emergency Measures”) was recently approved by the Japanese Cabinet. The package includes special tax measures for businesses, such as reductions to fixed asset and property taxes, the deferral of tax payments and social security premiums, and exemptions from National Pension Insurance and National Health Insurance premium payments.

The IRS has expanded favorable guidance regarding the delay of filing US federal individual income tax and related returns, as well as certain tax payments – welcome news for mobile workers who may be present in an unexpected location due to the health crisis. To assist mobility professionals, the table presented in this Insight is intended to provide a short-hand reference tool, coupled with some practical tips to consider.

Tax relief measures for businesses in the ‘Coronavirus Aid, Relief, and Economic Security Act’ (the CARES Act) include a five-year net operating loss (NOL) carryback (including a related technical correction to the 2017 ‘Tax Cuts and Jobs Act’ (the TCJA)) and a change in Section 163(j) interest deduction limitations. These measures give businesses greater ability and flexibility to use NOLs and interest deductions to offset their taxable income, providing them with liquidity and a reduced cost of capital as they grapple with the economic effects of the pandemic.

Following the impact of COVID-19, we have set out a quick guide for commercial tenancies. This includes a summary of the type of commercial leases that are covered by the forfeiture moratorium as a result of the Coronavirus Act 2020, as well as some examples in the market that commercial landlords and tenants are taking.

As the COVID-19 global response evolves, organisations are experiencing significant operational, financial and liquidity challenges. Read more on the key steps that should be considered by treasury teams as they respond to the impact of these challenges.

The recently enacted Coronavirus Aid, Relief, and Economic Security Act (CARES Act), includes a net operating loss (NOL) carryback provision allowing an NOL from tax years beginning in 2018, 2019, or 2020 to be carried back five years. The provision temporarily removes the current-law taxable income limitation and allows an NOL to fully offset income. The provision also makes a retroactive correction to the 2017 tax reform legislation to allow NOLs arising in a fiscal tax year beginning in 2017 and ending in 2018 to be carried back two years.

The European Commission has made recent announcements and released guidance to help organisations address social security implications for displaced workers due to COVID-19.

Australia has announced a range of measures in response to the COVID-19 crisis that broadly are consistent with the global response, including economic stimulus and cash flow support measures. Measures specifically related to international tax and transactions include: 1) administrative guidance around residency and permanent establishment (PE) issues arising due to travel restrictions; 2) changes in the Foreign Investment Review Board (FIRB) framework for assessing transactions; and 3) stimulus measures that could affect cross-border transactions, including accelerated depreciation and instant asset write-offs.

The Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), signed into law by the President on 27 March 2020, delivers relief in the form of an immediate payment from the IRS for certain individuals, including many mobile employees. Mobility programs should evaluate the impact of these potential payments and the related tax credit on their mobile populations, programs, and policies.

The Central Provident Fund (CPF) Board has announced that CPF is not required on the reimbursement of expenses incurred by employees for working in different locations (i.e., not the normal place of work) due to COVID-19 and such expenses are used to defray meal, transport, lodging, or utility expenses subject to meeting certain conditions.

As New Zealand headed towards a lock-down under Level 4 of the COVID-19 alert level system, Parliament passed legislation under urgency on 25 March 2020 to give effect to the Government’s COVID-19 economic support package. See this summary of the key features.

Businesses must take what was put into place post-federal tax reform and post-Wayfair and adapt it to a rapidly changing situation. This Insight is intended to provide a framework for approaching these issues; we plan to follow up with additional tools and issue-specific Insights in the weeks ahead.

The Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), signed into law by the President on 27 March, 2020, delivers relief in the form of an immediate payment from the IRS for certain individuals, including many mobile employees. Mobility programs should evaluate the impact of these potential payments and the related tax credit on their mobile populations, programs, and policies.

In this recent webcast our advisors discussed the key issues we are all working through and the longer-term impacts of COVID-19 on business continuity.

The Senate late on March 25 voted 96 to 0 to pass a $2 trillion “Phase Three” COVID-19 economic stabilization package, H.R. 748, the ‘Coronavirus Aid, Relief, and Economic Security Act’ (the CARES Act), that features significant tax provisions and other measures to assist individuals and businesses impacted by the economic effects of the COVID-19 pandemic. The House passed the CARES Act without change and President Trump signed the legislation into law on March 27, 2020.

Taxpayers and practitioners have had many questions about the status of IRS operations during the current pandemic. The IRS press release issued on March 24 answers some of those questions. The IRS People First Initiative unveiled on March 25 provides more clarity. At the same time, unresolved issues remain around the rapidly evolving situation. We will continue to request additional clarifications from the IRS and will provide updates on this fluid and challenging situation.

HMRC has announced this week that for UK income tax self assessment, any second payments on account due 31 July 2020, are deferred automatically until 31 January 2021. No penalties or interest for late payment will be charged. This is a change from earlier HMRC guidance which originally restricted the measure to the self-employed.

On 26 March HMRC provided much welcomed further details for employers on its Coronavirus Job Retention Scheme (CJRS), and also published guidance for employees.

Cash preservation and generation is the number one priority for many businesses. R&D claims are cash generating regardless of a company’s tax position and are therefore a way in which companies can accelerate cash into the business. Companies should also be considering other ways to maximise cash tax deductions, particularly in terms of capital expenditure and other incentives.

The recent global outbreak of COVID-19, which was declared a pandemic by The World Health Organisation on 11 March 2020, has not only impacted small businesses and markets across the world, but significantly impacted the UK real estate industry.

Read this PwC EUDTG newsalert on the adoption by the European Commission of a temporary State aid framework enabling EU Member States to support their economies during the COVID-19 crisis.

Following the Malaysian Government’s implementation of the Movement Control Order from 18 March to 31 March 2020 to control the spread of COVID-19, the Malaysian Inland Revenue Board (MIRB) announced on 17 March 2020 that tax return filing and balance of tax payment deadlines falling between March 2020 until June 2020 have been extended up to two months.

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. This issue includes items on responding to the business impacts of COVID-19.

We have released a special Covid-19 edition of our Global Employment Taxes Newsletter. This focuses on the latest employment taxes and immigration updates from governments around the world in response to the Covid-19 threat.

Following announcements at Budget 2020, HMRC has introduced measures to support businesses and the self-employed concerned about their ability to pay their tax liabilities due to the impact of Covid-19 by altering the details of their Time to Pay service.

In this TaxTalk Alert, we summarise the relief currently available to businesses at both the Federal and State level, including administrative concessions announced by the Australian Taxation Office (ATO).

The Chancellor announced that the Government is going to cover up to 80% of the current wage level of an employee who is designated as a “furloughed” worker, due to the Coronavirus pandemic, provided they are kept on the employer’s payroll. There will be a ceiling of £2,500 a month on salaries to which this applies. Employers can still top up salaries above this level if they choose to.

HMRC published welcome clarity on their views as to when additional time in the UK, due to COVID-19, would count as exceptional circumstances.

Treasury Secretary Steven Mnuchin on March 17 announced that individuals can defer tax payments up to $1 million for 90 days and corporations can defer tax payments up to $10 million for the same period. Specific details on tax payment relief were announced today by the IRS.

Yesterday we reported that, against the backdrop of the challenges posed by the Coronavirus (COVID-19), the Government has announced that implementation of the new IR35 off payroll working rules, which are to apply to large and medium sized businesses in the private sector, are to be delayed from 6 April 2020 until 6 April 2021. The Government has been clear that this is a deferral and not a cancellation.

Against the backdrop of the challenges posed by the Coronavirus (COVID-19), the Government announced last night that implementation of the new IR35 off payroll working rules, which are to apply to large and medium sized businesses in the private sector, are to be delayed from 6 April 2020 until 6 April 2021.

President Trump on March 13 declared a national emergency to address COVID-19. The President’s declaration instructs the Treasury and the IRS to provide relief from tax filing deadlines to individuals and businesses, as appropriate. Specific details on disaster tax relief, including new filing deadlines and eligibility requirements, are expected to be announced by the Treasury Department and the IRS.

On 12 March 2020, the Federal Government announced its comprehensive package (AUD17.6 billion) of measures to respond to the current economic challenges confronting the Australian economy as a result of the continued spread of the coronavirus (COVID-19). The focus of the package is on “backing business and keeping Australians in jobs” and from a tax perspective, includes significant concessions for capital investment from today in the form of enhanced tax write-offs for depreciable assets, as well as cash flow assistance to small and medium-sized businesses.