Ireland: 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 MoreOECD: Comments on proposed changes to the commentary on Article 9 of the OECD Model
On 3 June 2021 the OECD published comments received from interested parties in response to a public discussion draft on proposed changes to the commentary to Article 9 (associated enterprises) of the OECD Model Tax Convention. The comments will be
See MoreEU: European Commission sets out future agenda for business taxation
On 18 May 2021 the European Commission adopted a Communication on Business Taxation for the 21st Century setting out its vision for supporting business during the economic recovery and achieving fairer taxation. Ensuring effective
See MoreOECD case study on combating international tax avoidance in Senegal
On 21 May 2021 the OECD published a Tax and Development Case Study entitled “Fighting International Tax Avoidance and Evasion to Finance the Emergence of Senegal”. Senegal aims to be an emerging economy by 2035, and a ten-year development
See MoreOECD: Conference of the Parties to the MLI approves an opinion on interpretation and implementation
On 3 May 2021 an opinion of interpretation and implementation was reached by a conference of the parties to the multilateral instrument (MLI) for inclusion in bilateral tax treaties of the tax treaty related provisions arising from the action plan
See MorePeru: SUNAT clarifies interest deduction for thin capitalization rules
On 12 May 2021, the Peruvian Tax Administration (SUNAT) has issued Report No. 015-2021-SUNAT / 7T000 (the Guideline)regarding various queries related to the application of the limit for the deduction of interest expenses are answered, referred to
See MoreDenmark: Ministry of Taxation launches a public consultation regarding CFC rules
On 23 April 2021, the Ministry of Taxation announced a public consultation for amending a draft Bill L 89. This Bill proposes for an Act amending the Corporation Tax Act and the Capital Gains Tax Act (Implementation of the minimum requirements of
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