Bulgaria Ratifies MLI Convention
On 17 June 2022, Bulgaria ratified the OECD Multilateral Convention (MLI) (2017) and published it in the Official Gazette (No. Decree No. 153). Bulgaria also submitted its provisional MLI position at the time of signature, listing its
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Singapore: IRAS Publishes Updated E-Tax Guide on GST TP Adjustments
On 3 August 2022, the Inland Revenue Authority of Singapore (IRAS) updated the GST-E Tax Guide on Transfer Pricing Adjustments (Third Edition). The e-Tax guide explains the GST treatment for adjustments on the transfer prices of transactions between
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Ethiopia publishes investment incentives Law
On 12 July 2022, a new Investment Incentive Law No. 517/2022 was published by the Ethiopian Council of Ministers. The new Law aims to expand the scope of investment incentives and boost investment in Ethiopia. The law provides the following
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Russia updates the list of foreign states for automatic exchange of CbC reports
Recently, the Federal Tax Service of Russia published (Order No. ED-7-17/449) a new list of foreign states (territories), with which Russia will automatically exchange Country-by-Country (CbC) reports. Accordingly, the following states are
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French Court of Appeal of Paris clarifies TP rules for cross-border group companies
Recently, the French Court of Appeal of Paris issued a decision in the case of France v. Ferragamo France (No. 20PA0360), in June 2022, explaining the transfer pricing (TP) rules for cross-border group companies. The taxpayer (Ferragamo France),
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World Tax Brief: August 2022
Argentina Advance payments due: On 28 June 2022, Argentine Official Gazette published General Resolution 5211/2022 amending the provisions on income tax advance payment. The resolution increases the thresholds for making advance payments
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Russia: CBR cuts the Key Interest Rate to 8.0%
On 22 July 2022, the Central Bank of Russia (CBR) adopted a decision to cut the key interest rate from 9.5% to 8.0%. The key rate also impacts interest penalties, which are adjusted along with the adjusted key rate. For corporate taxpayers, the
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Dominican Republic publishes resolution on inflation adjustments
On 20 July 2022, the Dominican Republic tax authorities published a Resolution (DDG-AR1-2022-00006) on multipliers and adjustments for the fiscal year closing in June 2022. The Resolution includes the following changes: Set the inflation
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Germany enacts the bill on the interest rate for late payment
On 21 July 2022, The Ministry of Finance published the bill providing for a reduced rate for late interest payments on excess payments and refunds of tax in the Official Gazette. The bill had been previously approved by the lower house of the
See MoreGreece publishes lists of Jurisdictions for Automatic Exchange of Information on CbC reporting
Recently, the Ministry of Finance published a decision containing the list of jurisdictions to which it will apply the OECD Agreement on the Automatic Exchange of Information on Country-by-Country Reporting (CbC) (2016) in 2022 concerning the
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India: CBDT notifies the arm’s-length pricing variation limit for 2022-23
On 28 June 2022, the Indian Central Board of Direct Taxes (CBDT) issued Notification No. 70/2022, clarifying the calculation procedure of the arm’s length price under the income tax act. The notification provides a tolerance range of 1 % for
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Portugal extends the deadline to submit the TP file
On 6 July 2022, the government announced that it would extend the transfer pricing (TP) deadlines for preparation and/or submission to the tax authority. The deadline is extended from 15 July to 15 September 2022 without any accruals or
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Lithuania amends the APA rules
Recently, the State Tax Inspectorate of the Ministry of Finance of the Republic of Lithuania revised the Lithuanian Advance Pricing Agreements (APAs), which came into effect on 31 March 2022. Among other changes, the amendments also provide for
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Germany: MoF publishes a draft decree-law regarding the transfer of functions
On 5 July 2022, the German Federal Ministry of Finance published a draft decree-law regarding the transfer of functions. The aim of the draft decree-law is to adapt and restructure the existing regulations on the arm's length principle with the
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World Tax Brief: July 2022
Bangladesh Corporate income tax rate: On 9 June 2022, the Finance Minister of Bangladesh presented the national budget for fiscal year (FY) 2022-2023 in the parliament. The budget reduces the tax rate for non-listed companies from 30% to
See MoreGreece enacts ATAD’s reverse hybrid rule
On 30 June 2022, the government of Greece enacted legislation implementing ATAD's reverse hybrid rule with retroactive effect from 1 January 2022. The rule does not apply to collective investment vehicles. The new rule applies to situations where
See MoreDominican Republic: DGII publishes clarifications on CbC Reporting for MNE
On 22 June 2022, the Directorate General of Internal Revenue (DGII) published a Notice (No. 18-22) clarifying Country-by-Country Reporting (CbC) for Multinational Enterprises (MNEs). The notice includes the following procedures: Submit CbC
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Austria: MOF Updates Guidance on COVID-19 treaty Issues
On 20 June 2022, the Ministry of Finance published a Circular (no. 2022-0.433.029 of 17 June 2022) clarifying various tax treaty issues that have arisen due to the COVID-19 pandemic, including permanent establishments(PE) and the application of the
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