South Africa introduces draft interpretation on definition of “associated enterprises”
On 14 October 2022, the South African Revenue Service (SARS) published a draft interpretation note on the definition of "associated enterprise" for public comment. This draft note provides guidance on the interpretation and application of the
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Zambia: MoF presents 2023 Budget
On 30 September 2022, the Minister of Finance (MoF) proposed the 2023 Budget to the National Assembly. The important tax measures of the budget include: Reduce the corporate income tax rate from 30% to 25% on income earned from value addition
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France: Court decides the statute of limitations for recovery of taxes
Recently, the Administrative Court of Montreuil issued a decision regarding the statute of limitations for the recovery of tax claims following a collection notice. The statute of limitations for recovery is 4 years, although this may be extended by
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Germany: CJEU has issued a decision on sanctions for non-compliance with TP documentation requirements
On 13 October 2022, the Court of Justice of the European Union (CJEU) ruled in case: C-431/21 on sanctions for non-compliance with transfer pricing (TP) documentation requirements. Under German law, there is a rebuttable presumption that the
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World Tax Brief: October 2022
Angola Withholding tax rate-Others: On 22 August 2022, Angola published Law no. 27/22 in the Official Gazette amending the Corporate Income Tax Code. Accordingly, the withholding tax (WHT) rate on services paid to non-residents has been
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South Africa deposits ratification instrument for MLI
On 30 September 2022, South Africa deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI will come into effect for
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Greece amends corresponding adjustment provisions for Transfer Pricing
On 23 September 2022, Greece published Law No. 4972/2022 in the Official Gazette containing various tax measures including transfer pricing. The law amends an existing provision on transfer pricing adjustments upwards to provide for corresponding
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Pakistan: FBR extends the date of filing Income Tax Returns
On 30 September 2022, the Federal Board of Revenue (FBR) issued Circular No. 16 of 2022 and extended the date of filing income tax returns for the tax year 2022. According to the circular, the FBR extended the date for annual return filing up to 31
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Bulgaria Deposits Instrument of Ratification for MLI
On 16 September 2022, Bulgaria deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI). The Convention will enter into force in relation to Bulgaria on 1
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Russia: CBR cuts interest rate again
On 16 September 2022, the Central Bank of Russia (CBR) adopted a decision to cut the key interest rate from 8.0% to 7.5%. The key interest rate is used for the purposes of calculating interest deductions and late payment interest on overdue
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Oman introduces tax exemptions for sectors of economic diversification
On 8 September 2022, the Oman Tax Authority (OTA) announced some conditions and procedures for obtaining income tax exemption for companies operating in sectors contributing to economic diversification. The exemption is offered only to companies
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Dominican Republic: DGII Publishes general standard rule on MAP
On 30 August 2022, the Dominican Tax Authorities (DGII) issued a new general standard rule on Mutual Agreement Procedures (MAP) for Dispute Resolution under the country's tax treaties. The general rules introduced details for submitting MAP
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World Tax Brief: September 2022
Argentina Advance payments due: On 16 August 2022, the Argentine tax authority published General Resolution No. 5248/2022, requiring a one-time tax payment for certain large companies that benefitted from deducting losses due to the
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South Africa: National Assembly approves BEPS MLI
On 31 August 2022, the South African National Assembly (NA) approved the Multilateral Convention to Implement Tax Treaty-related measures to prevent Base Erosion and Profit Shifting (MLI). The MLI will generally enter into force for a particular
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Russia proposes to raise tax evasion thresholds
On 18 August 2022, the government launched a consultation on a proposal to raise the thresholds for tax evasion by legal entities. Accordingly, the criminal liability thresholds are amended as follows: The proposed threshold for large-scale tax
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Greece introduces new tax incentives
On 29 July 2022, Greece enacted legislation (Bill 4957/2022) that provides new research and development (R&D) tax incentives for companies. The law includes the following measures: -Provision of a deduction for R&D-related business
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Singapore amends regulations on CbC reporting agreements
On 11 August 2022, the Ministry of Finance published an amended Regulation No. S 669 on Country-by-Country (CbC) Reporting Agreements in the Official Gazette. The Regulation includes the following changes: Certain companies are required to file
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Lithuania approves draft bill relating to the VAT registration threshold for related persons
On 12 August 2022, the Lithuanian Parliament accepted for consideration Bill (No. XIVP-1915), relating to the VAT Law on Calculating the VAT Registration Threshold for Related Persons. Accordingly, when related persons carry out economic
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