Azerbaijan modifies the Tax Code for TP, CbC Reporting, and CFC rules
On 16 November 2021, Azerbaijan has modified its Tax Code including three main changes regarding Transfer Pricing (TP), country by country (CbC) reports, and controlled foreign company (CFC) rules. The changes will be implemented from 1 January
See MoreSouth Africa: Parliament tables 2021 Tax Bills
On 11 November 2021, Tax Bills 2021 (Taxation Laws Amendment Bill (TLAB), Tax Administration Laws Amendment Bill (TALAB), Rates and Monetary Amounts and Amendment of Revenue Laws Bill (Rates Bill)) were tabled in the Parliament. The National
See MorePoland: President signs new tax bill into Law
On 15 November 2021, the President signed into the Law a bill referred to as "Polski Ład" introducing, amongst others, amendments to the definition of a controlled foreign corporation (zagraniczna jednostka kontrolowana, CFC) to include more
See MoreFinland announces to amend interest deduction limitation rules
On 4 November 2021, the government of Finland has published a proposal to the interest deduction limitation rules. The proposed amendments are particularly relevant for companies that rely on the “balance sheet test” which provides for an
See MoreUN: Committee of Tax Experts Discuss Model Treaty Provisions
The virtual meetings of the UN Committee of Experts on Tax Matters taking place from 19 to 28 October 2021 are considering issues arising from the UN Model Tax Convention that should be the subject of future discussion within the UN
See MoreNetherlands: Amendments to revise CIT rate proposes for 2022 tax plan
On 5 October 2021, the amendments to the “2020 Tax Plan” were presented to the lower house of Parliament of the Netherlands. Further amendments to the “2022 Tax Plan” were presented on 15 October 2021 to the lower house of Parliament. The
See MoreIreland: Finance Ministry delivers the Budget 2022
On 12 October 2021, the Finance Ministry presented Budget 2022, which covers the following tax measures: The new minimum effective corporation tax rate will be 15%. However, Ireland will continue to offer the 12.5% rate for businesses with
See MorePoland: Lower chamber of parliament passes the tax reform bill
On 1 October 2021, the lower chamber of parliament (the Sejm) of Poland has passed the 3rd reading the bill for the so-called “Polish Deal” tax reform bill. The bill proposes to several tax reform measures including new minimum corporate tax,
See MorePoland: Government plans to extend the scope of CFC rules
On 8 September 2021, the Polish government submitted a bill to the Parliament including the proposal extending the application of the CFC rules. The proposal includes the following changes: Extension of the definition of a foreign legal entity
See MoreIreland: Government publishes Tax Strategy Group Papers prior to Budget 2022
On 16 September 2021, the Finance Department and the Department of Employment Affairs and Social Protection published Tax Strategy Group papers prior to Budget 2022. Some of the changes in the Budget papers are given below: Corporate tax As
See MoreIreland: Revenue updates TP rules for some qualifying companies
On 6 September 2021, the Revenue updated its guidance to assist some qualifying companies in accordance with Section 110 regarding the application of transfer pricing (TP) rules and other issues. Under Section 110, a company be a qualifying one if
See MoreMexico: Executive Branch submits 2022 economic proposal to Congress
On 8 September 2021, the Mexican Executive Branch has submitted Economic Package for the fiscal year 2022 including a proposal of Tax Reform. The proposed 2022 Tax Law clarifies income tax law, value-added tax (VAT) law, excise tax (duty)
See MoreKorea: MOEF proposes Tax Revision Bill 2021
On 26 July 2021, South Korea’s Ministry of Economy and Finance (MOEF) has issued an overview of the proposed Tax Revision Bill 2021 to support new industries and employment, as well as inclusive growth. The Tax Revision Bill 2021 includes the
See MoreOECD: Updates to Transfer Pricing Country Profiles
On 3 August 2021 the OECD issued an updated version of some of its transfer pricing country profiles, These include new country profiles for Angola, Romania and Tunisia, and updated profiles for seventeen other countries. The updated profiles have
See MoreUkraine: STS releases guidance letter on tax treaty requirements under CFC rules
On 12 July 2021, the State Tax Service (STS) has issued a guidance letter 2712/IPK/ 99-00-21-02-02-06 which clarifies tax treaty requirements under CFC rules. The guidance letter clarifies that from 1 January 2022 CFC profits may be exempt from
See MoreCanada: The Budget implementation Bill 2021 receives Royal Assent
On 29 June 2021, the 2021 Budget Implementation Act (“Bill C-30”) received Royal Assent, which includes certain tax measures that were proposed in the 2021 Federal Budget, the 2020 Fall Economic Statement, and the 2019 Federal Budget. Bill
See MoreBrazil: Executive Branch sends second phase of draft tax reform to Congress
On 25 June 2021, the Executive Branch sent the second stage of the tax reform proposal to Congress. This Tax reform includes the following changes: Government proposed to reduce the corporate income tax rate from 15% to 12.5% in 2022 and to 10%
See MoreDenmark: Parliament approves ATAD amendments to CFC rules
On 3 June 2021, the Danish Parliament approved a Bill L 89 to amend the controlled foreign company (CFC) rules with the purpose of bringing them in line with the EU Anti-Tax Avoidance Directive (ATAD). The major mechanism in the Danish CFC rules
See More