OECD: Summary of progress on Amount A of Pillar One
On 11 July 2022 the OECD published for consultation a Progress Report on Amount A of Pillar One. Further input is invited from commentators by 19 August 2022 in relation to the technical design of Amount A. Following the Statement on the
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OECD: Report to G20 Finance Ministers
On 11 July 2022 the OECD published the Secretary General’s report to the G20 Finance Ministers and Central Bank Governors for their July 2022 meeting. Two-pillar international tax deal The report notes that the technical work on the 15%
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Poland: MoF proposes important amendments to corporate income tax law
On 28 June 2022, the Polish government announced a draft law to proposing significant changes to the Polish Corporate Income Tax Act. The proposed changes impact the following areas; The effective date of the new “minimum tax” will be
See MoreKenya: President gives assent to the finance act 2022
On 21 June 2022, Kenya’s President has given his assent to the Finance Act 2022 which was presented to the Parliament on 13 April 2022. The act contains following tax measures mostly take effect on 1 July 2022. The Bill proposed to introduce
See MoreLuxembourg: Tax Authority updates guidance on CFC rules
On 17 June 2022, the Luxembourg Tax Authority published Circular n°164ter/1 (the guidance) on the controlled foreign corporation (CFC) rules. The guidance includes the following topics: Foreign controlled companies with regard to corporate
See MoreKenya: Corporate tax measures in Finance Bill 2022
On 12 April 2022, the Finance Bill 2022 was presented in the National Assembly of Kenya, which provides following tax measures related to corporate taxation. Corporations donating money to non-profit organizations can deduct the donation from
See MoreGreece: Government introduces new rules for interest deduction restriction
On 28 March 2022, Government published Law No. 4916/2022, which establishes new group escape rules for the 30% of EBITDA interest deduction restriction. The new group scape rule was made optional when the Greek interest restriction rules were
See MoreTaiwan: CFC rules will be effective from 2023
On 16 March 2022, Taiwan’s Ministry of Finance (MOF) issued a press release where it is stated that the controlled foreign company (CFC) rules will be effective from 1 January 2023 for individuals and 2023 taxable year for
See MoreCanada: Finance Department invites public comments on draft tax proposals
On 4 February 2022, the Canadian federal government released draft legislation to implement a variety of proposed tax measures including the new "Excessive Interest and Financing Expenses Limitation" (EIFE Limit) first announced in the April 2021
See MoreGreece: AADE issues a Circular to provide guidance on CFC rules
On 23 February 2022, the Greek Public Revenue Authority (AADE) published Circular E. 2018 of 23 February 2022, providing guidance on the application of Controlled Foreign Companies (CFC rules). This is introduced as from 1 January 2019 in line with
See MoreUruguay revises list of low or no tax jurisdictions
On 21 February 2022, Uruguay has published DGI Resolution No. 223/022, which updates the list of low or no tax jurisdictions and regimes, with effect from same date. According to the Resolution No. 223/022 the updated list includes 36
See MoreOECD Tax Talk looks at international tax developments
The OECD Tax Talk held on 21 February 2022 provided an updated on important elements of tax work at the OECD. Two-Pillar International Tax Package Public consultations have begun and will cover the various building blocks of Pillar One on a
See MoreCanada: Public comments of draft tax Proposals for Certain Budget 2021
On 7 February 2022, the Department of Finance released for public comment a set of draft legislative proposals to implement previously announced and other tax measures. Specifically, the proposals would implement Budget 2021 measures to: Allow
See MoreSwitzerland: Review of international financial and tax developments in 2021
On 25 January 2022 Switzerland’s State Secretariat for International Financial Matters published its summary for 2021 entitled: Swiss financial and tax centre in 2021: more sustainable, more digital and in good shape despite the pandemic. The
See MoreBulgaria approves amendments to the CIT Act
On 20 January 2022, the Bulgarian Parliament passed the draft law amending and supplementing the Corporate Income Tax Act (CITA). The draft law provides for the implementation of the reverse hybrid mismatch rules of the EU Anti-Tax Avoidance
See MoreOECD releases latest edition of the Transfer Pricing Guidelines
On 20 January 2022 the OECD released the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The latest edition of the guidelines includes changes made to the 2017 edition by reports issued by
See MoreIreland: President signs Finance Bill 2021 into Law
On 21 December 2021, President signed the 2021 Finance Bill into Finance Act 2021, which provides for the implementation of the 2022 Budget measures as well as some necessary anti-avoidance measures and technical changes to the tax code. Some of
See MoreItaly: IRA Publishes guidance on CFC legislation
On 27 December 2021, the Italian Revenue Agency (IRA) has issued the publication of Circular No. 18/E, that provides guidance regarding the regulations for controlled foreign companies (CFCs) as amended by Article 4 of Legislative Decree No.
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