Taiwan: 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.
See MoreIndia: CBDT notifies the arm’s-length pricing variation limit for 2021-22
On 29 October 2021, the Central Board of Direct Taxes (CBDT) has published Notification No. 124/2021, which provides for a tolerance limit of 1% for wholesalers and 3% in all other cases for the arm’s-length pricing determination in the
See MoreAzerbaijan 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
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