India: SC finds Mitsubishi is not liable for interest on late advance tax
On 17 September 2021, in the DIT vs Mitsubishi Corporation case, the Supreme Court ruled that a taxpayer should not liable for interest on late tax advances prior to fiscal 2012/2013 if the income payer failed to deduct the tax at source. The
See MoreUkraine: STS clarifies the controlled transactions criteria for TP purposes
Recently, the State Tax Service (STS) has clarified the criteria for classifying transactions between related parties (Ukrainian residents and non-residents) as controlled for transfer pricing (TP) purposes. Under Ukrainian transfer pricing
See MoreRussia increases the interest rate from September 2021
On 10 September 2021, the Russian Central Bank has announced the decision to increase the key rate from 5.5% to 6.75% with effect from 13 September 2021. For tax purposes, the key rate is important in relation to the safe harbor rates for
See MoreUkraine: MOF approves three Orders on transfer pricing and other taxes
On 20 August 2021, the Ukraine Ministry of Finance announced the issuance of three orders that approve tax clarifications/consultations on: Issues of taxation of income of non-residents, which are equated to dividends (Order №
See MoreDenmark plans to make permanent the tax incentives for R&D
On 7 September 2021, the Danish government proposed to make permanent the current temporarily increased deduction for research and development expenses of companies under an economic and social plan. An increased deduction of 130% of R&D
See MoreSingapore: MOF responses to public consultations on the draft ITA Bill 2021
On 3 September 2021, the Ministry of Finance (MOF) published its responses to feedback provided as part of the public consultation exercise conducted in connection with the draft Income Tax (Amendment) Bill 2021, which proposed a number of
See MoreIndia further extends due dates of ITR for FY 2021-22
On 9 September 2021, the Central Board of Direct Taxes (CBDT) has issued a press release announcing the deadline extensions for filing income tax returns and various audit reports for the 2021-22 tax year due to some difficulties reported by
See MoreRussia introduces reduced rate for IP income
On 31 August 2021, the Federal Tax Service has published a clarification. Accordingly, from 2 August 2021, regions of Russia may set a reduced corporate income tax rate for the income received by taxpayers from the provision of rights to use the
See MoreBotswana: General Commissioner sets TP documentation threshold
On 1 September 2021, the General Commissioner published a ruling and set a threshold for the preparation and submission of transfer pricing documentation. The ruling is effective retroactively from 1 July 2019 (2020 tax year). According to the
See MoreWorld Tax Brief: September 2021
Botswana Withholding tax rates: On 30 June 2021, the Minister of Finance and Economic Development enacted the budget for 2021/22. Accordingly, the general withholding tax rate increased from 7.5% to 10% on dividends paid to both resident and
See MoreGermany publishes Guidance on MAP and arbitration procedures
On 27 August 2021, the Federal Ministry of Finance published guidance on mutual agreement (MAP) and arbitration procedures. The guide explains how to initiate procedures, how to carry out procedures, how to execute agreements, etc. The guidance
See MoreIndia extends the due dates for E-filing of various forms
On 29 August 2021, the CBDT published circular No. 16/2021 to extend the deadlines for the electronic submission (E-filing) of various forms. Accordingly, the due date for filing the CbC report notice (i.e. Form 3CEAC) may be submitted on or before
See MoreDenmark presents Budget for 2022
On 30 August 2021, the Minister of Finance presented the government's budget proposal for 2022. With its proposal for the Finance Act 2022, most of the measures presented focus on easing the country's transition out of the crisis and include a
See MoreRussia: MOF clarifies the deductibility of R&D expenses for CIT purposes
The Russian Ministry of Finance (MoF) recently issued a Guidance Letter No. 03-03-06/1/49733, published on July 26, 2021. The MoF noted that R&D expenditure was completed in the reporting period (tax period) in which this R&D was completed
See MoreGerman: Federal Constitutional Court voids 6% interest rate on back taxes
On 18 August 2021, the Federal Constitutional Court has published a press release stating that interest of 6% pa on tax back payments and tax refunds from 2014 is unconstitutional. Earlier, the First Senate of the Federal Constitutional Court
See MoreIndia: CBDT notifies a formula to adjust MAT relief for secondary adjustment and APA
On 10 August 2021, the Central Board of Direct Taxes (CBDT) has published Notification No. 92/2021, which contains a new rule for calculating tax relief in the event of an increase in book profit as a result of adjustments to Advance Pricing
See MoreGermany updates the CbC Reporting requirements based on the Annual Tax Act 2020
The Federal Ministry of Finance recently published a notice on the current issue of the Federal Central Tax Office's newsletter, which updates the country-specific (CbC) reporting requirements due to the 2020 Annual Tax Act. As a result of the
See MoreDenmark proposes to reduce the TPD obligation for purely Danish transactions
On 23 June 2021, the Ministry of Finance submitted a draft bill for consultation. The bill proposed an amendment to the Danish Tax Control Act in order to relax the documentation requirements for transfer pricing for purely Danish transactions. It
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