Renewables are an expensive substitute for Indonesia's coal dependence
Various important themes and topics were discussed at this year’s COP26 and Indonesia was one of the countries that faced growing pressure at the summit.
On April 19, 2021 (Budget Day), the Minister of Finance of Canada, the Hon. Chrystia Freeland, tabled the Federal Budget for 2021 (Budget 2021). Budget 2021 is the first budget in more than two years and provides for billions of dollars in new spending to finish the fight against COVID-19 and ensure a strong economic recovery.
Some of the key tax measures proposed by Budget 2021 include the introduction of the new Canada Recovery Hiring Program, new incentives to support clean emission activities and projects, new reporting requirements for certain aggressive transactions and new measures to fight base erosion and profit shifting (including the introduction of new interest deductibility limits and new rules targeting hybrid arrangements). Notably, Budget 2021 does not propose to increase corporate or personal tax rates, change the inclusion rate for capital gains or the rules governing the lifetime capital gains exemption or the principal residence exemption.
As the government is in a minority position in the House of Commons, there is no certainty that the proposed tax measures will be adopted as tabled.
Emergency Business Supports
Budget 2021 proposes to extend the Canada Emergency Wage Subsidy (CEWS) and the Canada Emergency Rent Subsidy (CERS) until September 25, 2021, with a gradual decline in the subsidy rate starting on July 4, 2021, and proposes to implement the Canada Recovery Hiring Program (CRHP), a new program aimed at incentivizing new hiring or wage increases for current employees.
Regarding the CEWS and the CERS:
The CRHP is proposed to provide eligible employers with a subsidy of up to 50% of the incremental remuneration paid to eligible employees between June 6, 2021, and November 20, 2021. Highlights of the CRHP include:
Immediate Expensing by Canadian-Controlled Private Corporations
Under the capital cost allowance (CCA) system in the Income Tax Act (Canada) (the Tax Act), taxpayers are entitled to deduct a portion of the capital cost of depreciable property in computing their income. Depreciable property is generally divided into CCA classes and a CCA rate for each class of property is prescribed in the Income Tax Regulations where the CCA deduction is computed on a declining balance basis.
The amount of CCA that can be claimed in the first year that a depreciable property becomes available for use is generally limited to half the amount that could otherwise be deducted (generally referred to as the "half-year rule"). On November 21, 2018, the federal government announced a temporary enhanced first-year allowance, referred to as the Accelerated Investment Incentive, equal to up to three times the previously applicable first-year allowance and the ability to immediately expense investments in certain machinery and equipment used in manufacturing or processing as well as certain clean energy generation equipment.
Budget 2021 proposes to allow CCPCs to immediately expense the full cost of certain depreciable property (referred to as "eligible property") acquired on or after Budget Day and that becomes available for use before 2024, up to a maximum of $1,500,000 per taxation year (to be pro-rated for short taxation years and shared among associated CCPCs) and subject to certain restrictions. The immediate expense in respect of eligible property would be available in the taxation year that such property becomes available for use and no carry-forward will be permitted for CCPCs with less than $1,500,000 of eligible capital costs.
The category of "eligible property" that may benefit from immediate expensing is broad, and generally includes all depreciable capital property, other than certain "long-lived assets" such as buildings, pipelines and other physical infrastructure, as well as goodwill. Accordingly, this proposal will allow CCPCs to immediately expense the full costs of many tangible items acquired in the course of business, including tools, computers, vehicles, machinery and other equipment, up to the maximum of $1,500,000 per taxation year.
The costs of depreciable property that do not benefit from the immediate expense treatment under this proposal would continue to be subject to the existing CCA rules, including the accelerated investment incentives and full expensing of certain clean energy equipment previously announced in 2018.
This measure would apply for eligible property that is acquired on or after Budget Day and that becomes available for use before 2024.
Clean Technology Incentives
As part of a continued effort to encourage investment in clean technology, Budget 2021 proposes to:
Reduced tax rates applicable to "eligible zero-emission technology manufacturing and processing income"
Budget 2021 proposes to temporarily reduce the federal corporate income tax rate applicable to "eligible zero-emission technology manufacturing and processing income" to 7.5% for income otherwise subject to the general federal rate of 15%, and 4.5% for income that would otherwise be subject to the federal small business rate of 9%.
These reduced rates are generally applicable only to income earned from certain zero-emission technology manufacturing and processing activities, such as the manufacturing of solar, hydro, wind and geothermal energy equipment, as well as the production of zero-emission vehicles and charging systems. Budget 2021 contains proposals as to how such eligible income is to be calculated and the government has invited feedback from stakeholders as to such calculations.
The reduced rates are proposed to be in effect for taxation years that begin after 2021 and before 2029, and would be gradually phased out between 2029 and 2031.
Expanded availability of preferred CCA regime for clean energy equipment
Certain incentives are available for clean energy equipment that is included in Class 43.1 and Class 43.2 for purposes of the CCA rules. In addition to ordinary depreciation rates of between 30% and 50%, property that is included in Class 43.1 and Class 43.2 is generally eligible for immediate expensing where it is acquired and becomes available for use before 2024. As Budget 2021 notes, certain expenses incurred in the development of a clean energy project that relies on equipment included in Class 43.1 and Class 43.2 can be treated as Canadian Renewable and Conservation Expense and deducted in full, or flowed through to shareholders under the flow-through share regime.
Budget 2021 proposes to expand the types of clean energy equipment that may be included in Class 43.1 and Class 43.2. Accordingly, certain clean and renewable energy equipment that was previously excluded, such as active solar and geothermal heating for pools, and hydrogen refueling equipment for vehicles, will generally be eligible for inclusion where it is acquired and becomes available for use on or after Budget Day.
Of note, Budget 2021 also proposes to remove certain equipment that relies on fossil fuels from Class 43.1 and Class 43.2, thereby denying the above-mentioned incentives for such equipment. Examples of such equipment include cogeneration systems and certain waste-fuelled systems that rely on fossil fuels for energy input. Such equipment will no longer qualify for Class 43.1 or Class 43.2 treatment where it becomes available for use after 2024.
Extension of the Timelines for Certain Film or Video Production Tax Credits
Budget 2021 proposes to temporarily extend certain timelines for the Canadian Film or Video Production Tax Credit (CPTC) and the Film or Video Production Services Tax Credit (PSTC) for productions for which eligible expenditures were incurred by taxpayers in their taxation years ending in 2020 or 2021.
With respect to the CPTC, Budget 2021 proposes to extend the following existing timelines by 12 months:
Regarding the PSTC, Budget 2021 proposes to extend by 12 months the 24-month timelines in respect of when aggregate expenditure thresholds must be met for film or video productions for the purposes of the PSTC.
For both the CPTC and the PSTC, taxpayers will be required to file a waiver with the Canada Revenue Agency (CRA) and the Canadian Audio-Visual Certification Office in order to extend the assessment limitation period in respect of the relevant years to take into account the 12-month extension.
Mandatory Disclosure Rules
Budget 2021 proposes consultations to enhance Canada’s disclosure rules for certain types of transactions, as recommended by the OECD Base Erosion and Profit Shifting (BEPS) Action 12 report.
Under the current provisions of the Tax Act, certain transactions entered into by, or on behalf of, a taxpayer are considered a "reportable transaction" if they are both an "avoidance transaction" and two out of three criteria (referred to in Budget 2021 as "generic hallmarks") apply to that transaction. Currently, an "avoidance transaction" generally means any transaction that would, directly or indirectly, result in a tax benefit unless it was undertaken or arranged primarily for bona fide purposes other than to obtain the tax benefit.
In general terms, the three criteria or generic hallmarks are:
For purposes of these rules, any transaction that is part of a series of transactions that includes the avoidance transaction can also be a reportable transaction. A reportable transaction must be disclosed to the CRA by June 30 of the calendar year following the year in which the transaction first satisfied the above conditions.
Budget 2021 notes that the existing provisions of the Tax Act "result in only limited reporting by taxpayers." Therefore, to improve the effectiveness of these rules and to bring them more in line with the recommendations under the BEPS Action 12 report, Budget 2021 proposes to make the following changes to the existing reportable transaction rules in the Tax Act:
Budget 2021 proposes to introduce a new, mandatory regime (modelled after those in the US, UK, EU and Australia) for reporting certain transactions of interest that have the potential for tax avoidance or tax evasion. Notifiable transactions would include transactions that the CRA has found to be abusive and transactions identified as transactions of interest. The description of a notifiable transaction would set out the fact patterns or outcomes that constitute that transaction in sufficient detail to enable taxpayers to comply with the rule. It would also include examples in appropriate circumstances.
Reporting would be required by taxpayers who enter into notifiable transactions (or a transaction or series of transactions that is substantially similar) within the same time periods described above for reportable transactions. Reporting would also be required of promoters and advisors, except if solicitor-client privilege applies.
Uncertain Tax Treatments
Budget 2021 notes, whereas US and Australian tax laws require reporting uncertain tax treatments (and the UK intends to implement its own law), there is no similar requirement under Canadian tax law. New rules are proposed in Budget 2021 that would bring Canada in line with those countries, and also with Canadian GAAP that currently requires all Canadian public companies, and those Canadian private companies that follow IFRS, to disclosure their uncertain tax positions on their consolidated financial statements.
The proposal to report uncertain tax treatments will apply to corporate taxpayers if each of the following conditions is met:
For each reportable uncertain tax treatment, the corporation will be required to provide prescribed information, such as the quantum of taxes at issue, a concise description of the relevant facts, the tax treatment taken (including the relevant sections of the Tax Act) and whether the uncertainty relates to a permanent or temporary difference in tax. The uncertain tax treatments would be required to be reported at the same time that the reporting corporation’s Canadian income tax return is due.
These proposals do not indicate if they would apply to entities other than corporations (such as trusts and partnerships) which otherwise meet the above criteria.
Reassessment Period and Penalties
Budget 2021 proposes that if a taxpayer fails to provide one of the mandatory disclosures noted above, the normal reassessment period for the relevant taxation year will not apply, and accordingly, the year would not become statute barred. Further, Budget 2021 also proposes that significant penalties would apply to taxpayers and promoters for each failure to report.
Avoidance of Tax Debts
The Tax Act contains a tax debt anti-avoidance rule that is intended to prevent taxpayers from avoiding tax liabilities by transferring their assets to non-arm's length persons for less than fair market value consideration. In certain circumstances, the tax debt anti-avoidance rule will make the transferee jointly and severally liable with the transferor for the tax debts of the transferor, to the extent of the value of the property transferred in excess of the consideration paid. Budget 2021 indicates that some taxpayers have engaged in complex transactions to circumvent the application of the tax debt anti-avoidance rule.
Budget 2021 proposes to amend the Tax Act to prevent taxpayers from circumventing the tax debt anti-avoidance rule through the introduction of new rules focusing on three main areas of concern:
Firstly, for the deferral of tax debts, in certain circumstances, Budget 2021 proposed to introduce an anti-avoidance rule under which the tax debt will be deemed to have arisen before the end of the taxation year in which a transfer of property occurs where it is reasonable to conclude that the (i) transferor (or a person that is non-arm’s length with the transferor) had knowledge or would have knowledge if they had made reasonable inquiries that there would be a tax amount owing by the transferor (or there would be a tax amount owing if not for additional tax planning done as part of the series of transactions that includes the transfer) that would arise after the end of the taxation year, and (ii) a purpose for the transfer of property was to avoid the payment of the future tax debt.
For the avoidance of non-arm’s length status, Budget 2021 proposes that the parties to a transfer of property will be deemed to have been non-arm’s length at that time if: (i) at any time within a series of transactions or events that includes the transfer, the parties do not deal at arm’s length and (ii) it is reasonable to conclude that one of the purposes of a transaction or event (or a series of transactions or events) was to cause the parties to the transaction to deal at arm’s length at the time of transfer.
In respect of valuations, Budget 2021 proposes to introduce a rule such that, for transfers of property that are part of a series of transactions, the overall result of the series would be considered. As such, the overall result would factor into the determination of the values of and consideration for the transferred property – and not, simply using the values at the time of the transfer.
Budget 2021 also proposes to introduce a penalty for planners and promoters of such tax debt avoidance arrangements that will be equal to the lesser of 50 per cent of the tax that is attempted to be avoided and $100,000 plus the promoter’s or planner’s compensation for the scheme.
These measures will apply to transfers of property that occur on or after Budget Day.
Expanding Audit Powers
Budget 2021 proposes to amend the Tax Act to clarify the audit and verification powers of CRA officials. Primarily, the proposed changes are aimed at requiring persons to respond to questions either orally or in writing, including in any form specified by the CRA official. Persons must continue to answer all proper questions, and to provide all reasonable assistance, for any purpose related to the administration or enforcement of the Tax Act. Irrespective of the federal government’s stance that this confirms previous powers, such amendments regarding demanding oral answers (and likely in-person meetings) are fresh CRA audit powers.
These measures would come into force upon royal assent.
Budget 2021 introduces two additional measures to further align Canada’s tax system with the objectives of the multinational BEPS project. Consistent with the BEPS Action Plan, Canada will adopt limits on interest deductibility and address "hybrid mismatch" arrangements.
Interest Deductibility Limits
Canada already imposes "thin capitalization" rules that limit the deductibility of interest when the ratio of debt owed to specified non-residents to equity exceeds 1.5:1. These rules have been strengthened considerably over the past 10 years, including with the adoption of the "back to back" loan rules. Nonetheless, Budget 2021 proposes to adopt a new earnings-stripping rule consistent with the BEPS Action 4 report, which will limit the amount of net interest expense that may be deducted to a fixed share of earnings. The budget materials state it is expected that standalone Canadian corporations and Canadian corporations that are members of a group with no non-resident members would in most cases not be affected by the earnings-stripping rule.
Under the proposed rule, the amount of net interest expense that a taxpayer may deduct in computing its taxable income is limited to no more than a fixed ratio of "tax EBITDA." The tax EBITDA, is the corporation’s taxable income before interest expense, interest income and income tax, and deductions for depreciation and amortization. Each of these terms will be defined for purposes of the Tax Act, but in general:
The new earnings-stripping rule will apply to corporations, trusts, partnerships and Canadian branches of non-resident taxpayers.
CCPCs that, together with associated corporations, have taxable capital employed in Canada of less than $15 million will be excluded from the earnings-stripping provisions. Also excluded will be groups of corporations and trusts whose aggregate net interest expense among Canadian members is $250,000 or less.
The proposals address these additional further issues:
The ratio of net interest to tax EBITDA will be set at 40% for taxation years beginning on or after January 1, 2023, but before January 1, 2024, and will be 30% for all subsequent years. Special rules will apply to determine the ratio applicable where non-deductible interest is carried back to a prior year.
This measure is proposed to apply to taxation years that begin on or after January 1, 2023, and an anti-avoidance measure has been proposed (which has not been set out) to prevent taxpayers from deferring the application of the rule, or of the 30% ratio. In addition, this measure will apply to existing borrowings, not just those incurred after January 1, 2023. Budget 2021 indicated that draft legislation will be released for comment in the summer of 2021.
Hybrid Mismatch Arrangements
Hybrid mismatch arrangements are cross-border tax structures that take advantage of differences in the income tax treatment of business entities or financial instruments under the laws of two or more countries to produce mismatches in tax results. The BEPS Action 2 report detailed rules for adoption in domestic legislation to deny tax benefits from the use of hybrid mismatch arrangements in a coordinated international manner. While the Department of Finance Canada concluded that there are existing Canadian income tax rules that the government can use to challenge certain hybrid arrangements, specific legislative measures would provide certainty and the benefits of a common international approach as proposed by the Action 2 report.
In general terms and consistent with the rules in the Action 2 report, Budget 2021 proposes that payments made by Canadian residents under hybrid mismatch arrangements would not be deductible for Canadian income tax purposes to the extent that they give rise to a further deduction in another country or are not included in the ordinary income of a non-resident recipient. In addition, to the extent that a payment made under such an arrangement by an entity that is not resident in Canada is deductible for foreign income tax purposes, Budget 2021 proposes that no deduction for the payment would be permitted against the income of a Canadian resident. Any amount of the payment received by a Canadian resident would also be included in income for Canadian tax purposes, and, if the payment is a dividend, it would not be eligible for the deduction otherwise available for certain dividends received from foreign affiliates.
The proposed rules to address hybrid mismatch arrangements are suggested to be implemented in two separate legislative packages. The first package, intended to be released for consultation later in 2021 would have application as of July 1, 2022, and would comprise rules to neutralize certain deduction/non-inclusion mismatches. The second legislative package would be released for stakeholder comment after 2021, with application no earlier than 2023. The second package would comprise rules consistent with the balance of Action 2 recommendations that were not addressed in the first package.
Budget 2021 included a number of relatively minor personal tax proposals, including the following:
Disability Tax Credit
Budget 2021 proposes to expand access to the disability tax credit (DTC) by broadening the definition of "mental functions necessary for everyday life" and expanding the inclusion of time spent on certain activities in determining the average weekly time spent receiving extensive life-sustaining therapy to better recognize certain aspects of therapy that may be excluded under the current rules.
This measure would apply to the 2021 and subsequent taxation years, in respect of DTC certificates filed with the CRA on or after the enacting legislation receives royal assent.
Canada Workers Benefit
The Canada Workers Benefit (CWB) provides a non-taxable, refundable tax credit to low- and modest-income workers based on the amount of "working income" earned by the eligible individual up to a particular threshold, at which point the benefit phases out at a specified rate in proportion to the "working income" earned above the phase-out threshold.
The phase-out threshold differs if the eligible individual also has an eligible spouse or an eligible dependant. Budget 2021 proposes to increase (i) the rate at which the benefit accrues, (ii) the phase-out threshold and (iii) phase-out rate, collectively resulting in expanded entitlement to the CWB. Corresponding changes are also proposed to the additional supplement that may be received by an eligible individual who is also eligible to receive the DTC. Budget 2021 also proposes to introduce a "secondary earner exemption" that would allow an eligible individual with an eligible spouse to exclude up to $14,000 of the secondary earner's income from the adjusted household net income for the purpose of determining whether the phase-out threshold has been met or exceeded.
This measure would apply to the 2021 and subsequent taxation years.
Northern Residents Deduction
Budget 2021 announced the intention to introduce the choice for a taxpayer to claim as a deduction, for each of the taxpayer and each "eligible family member" of the taxpayer, a new standard amount in respect of a given trip made for non-medical personal reasons, subject to the general limitations of the Northern Residents Deduction.
This measure would apply to the 2021 and subsequent taxation years.
Postdoctoral Fellowship Income
Budget 2021 announced that postdoctoral fellowship income received in the 2021 and subsequent taxation years will qualify as “earned income” for the purpose of determining an individual’s contribution limit for an RRSP, and taxpayers may request an adjustment to their RRSP contribution room for such income received in the 2011 to 2020 taxation years in writing to the CRA.
This measure would apply to postdoctoral fellowship income received in the 2021 and subsequent taxation years. This measure would also apply to postdoctoral fellowship income received in the 2011 to 2020 taxation years where the taxpayer submits a request to the CRA for an adjustment to their RRSP room for the relevant years.
Tax Treatment of COVID-19 Benefit Amounts
Budget 2021 proposes to amend the Tax Act to allow individuals the option to claim a deduction in respect of the repayment of a COVID-19 benefit amount in computing their income for the year in which the benefit amount was received rather than the year in which the repayment was made and to include COVID-19 benefit amounts in the taxable income of those individuals who reside in Canada but are considered non-resident persons for income tax purposes.
Fixing Contribution Errors in Defined Contribution Pension Plans
Budget 2021 announced that contribution errors in a defined contribution pension plan can be corrected through the filing, by the plan administrator, of a prescribed form for each affected employee rather than through a T4 amendment, for any of the preceding five years. Additional contributions made to correct an error would reduce the employee's RRSP contribution room for the taxation year following the year in which the retroactive contribution is made. Where the correction results in negative RRSP room, it will affect the employee's contributions in future years. Refunds of over-contributions will restore the employee's RRSP contribution room for the taxation year in which the refund is made.
This measure would apply to additional contributions made, and amounts of over-contributions refunded, in the 2021 and subsequent taxation years.
Taxes Applicable to Registered Investments
Budget 2021 proposes certain changes to Part X.2 tax imposed where a registered investment for a registered plan is in contravention of investment restrictions that require certain registered investments to only hold qualified investments for its type of registered plan. Specifically, Budget 2021 proposes that the Part X.2 tax be calculated on a pro-rata basis on the proportion of shares or units of the registered investment that are held by investors that are subject to the qualified investment rules, rather than the entire fair market value of the non-qualified investments held.
This measure will apply to taxes imposed under Part X.2 of the Tax Act for months subsequent to 2020. The measure will also apply to months before 2021 where the CRA has not finally determined the tax liability under Part X.2 of a taxpayer.
Amendments to the GST/HST E-Commerce Proposals
In the Fall Economic Statement 2020, the government proposed that:
Budget 2021 proposes to introduce the following amendments to the E-Commerce Proposals:
These new measures would come into force on July 1, 2021, with a 12 month transition period during which CRA would take a practical approach to compliance and exercise discretion in administering these measures.
Information Requirements for Input Tax Credits
Currently under the Excise Tax Act (Canada) (the ETA), businesses must obtain and retain certain prescribed information to support their input tax credit (ITC) claims depending on the amount paid for a supply. Budget 2021 proposes to increase the current ITC information thresholds to $100 (from $30) and $500 (from $150), as applicable, and to allow billing agents to be treated as intermediaries for purposes of the ITC information rules. These measures would come into force after Budget Day.
GST New Housing Rebate Conditions
Budget 2021 proposes to allow the rebate where a new home is acquired for use as the primary place of residence of any one of the purchasers (or of a related person), rather than only where all the purchasers so use the new home, generally with respect to a supply made under an agreement entered on or after Budget Day.
Tax on Select Luxury Cars, Aircraft and Boats
Budget 2021 proposes to introduce a new retail sales tax on new luxury cars and personal aircraft priced over $100,000, and boats priced over $250,000, purchased in or imported to Canada on or after January 1, 2022. The tax rate would be equal to the lesser of 10% of the full value of the luxury good or 20% of the value above the applicable threshold. The tax would be imposed at the final point of purchase (or at the time of importation if no further sale in Canada), and the GST/HST would apply to the final sale price, including of the proposed tax.
Excise Tax Measures
Budget 2021 contains the following proposals for excise tax:
Customs Duty and Tax Collection on Imported Goods
Budget 2021 proposes amendments to the Customs Act (Canada) to improve the collection of duties and taxes on imported goods by (i) ensuring that all importers value their goods using the value of the last sale for export to a purchaser in Canada and (ii) supporting a broad modernization of payment processes for commercial importers.
National Vacancy Tax on Foreign-Owned Canadian Housing
Budget 2021 announced the federal government’s intention to impose a tax on persons who are not Canadian citizens or permanent residents and who own residential property in Canada that is vacant or underused.
The proposed tax would be applied at an annual rate of 1% of the value of such vacant or underused housing and would be effective as of January 1, 2022.
All foreign owners of residential property in Canada would be required to file annual declarations (beginning in 2023) regarding the use of their residential property for the prior year, regardless of whether a property is subject to tax in the year. It is proposed that the failure to file a declaration for a property could result in penalties, interest and the loss of any otherwise available exemptions from the tax, in addition to causing the limitation period for assessment to be unlimited.
No specific legislation to enact this tax has yet been released. Rather, Budget 2021 announced that the federal government intends to release a backgrounder to stakeholders with an invitation to comment on other aspects of the proposed tax in the coming months. Some of the issues on which the federal government will be seeking consultation include how residential property should be defined, how value should be determined, how the tax should be applied in situations involving multiple owners, corporations and trusts, as well as what exemptions should be permitted. In addition, Budget 2021 indicates that this consultation will also involve considering whether the tax should be applied to smaller communities and to resort and tourism areas and, if so, when and how the tax should be applied to such locales.
In the 2020 Fall Economic Statement, the federal government announced that, in the absence of a multilateral approach among OECD member countries on cross-border taxation, Canada would move ahead to implement a tax on corporations providing digital services.
Without introducing enacting legislation, Budget 2021 proposes to implement a digital services tax at a rate of 3 percent on revenue from digital services that rely on data and content contributions from Canadian users. Budget 2021 proposes that the digital services tax would apply to large businesses with gross revenue of 750 million euros or more and would come into effect as of January 1, 2022, and will apply until an acceptable multilateral approach comes into effect.
Registration and Revocation Rules Applicable to Charities
Budget 2021 includes mechanisms to revoke a charity’s registration or suspend issuing official donation receipts in relation to terrorist funding purposes or false statements made by registered charities. The measures will apply on royal assent and include:
Electronic Filing and Certification of Tax and Information Returns
Budget 2021 also introduces a number of measures to improve the CRA’s ability to operate digitally, including the following measures to be effective after receiving royal assent of the enacting legislation:
In addition, Budget 2021 included additional measures relating to the electronic filing of tax and information returns, remittance of tax and the certification of tax and information returns.
Previously Announced Measures
Budget 2021 also confirmed the government’s intentions for previously announced tax measures, as modified to take into account consultations and deliberations since their release, including:
Various important themes and topics were discussed at this year’s COP26 and Indonesia was one of the countries that faced growing pressure at the summit.
© Norton Rose Fulbright LLP 2021