Russia clarifies transfer pricing rules for foreign entities with permanent establishments
Russia’s Ministry of Finance (MOF) has issued a guidance letter No. 03-12-12/1/59174 clarifying the transfer pricing obligations for controlled transactions involving foreign legal entities operating through permanent establishments (PEs) in
See More
India: Access to foreign booking systems by domestic entities does not establish a taxable presence
The Delhi Bench of India's Income-tax Appellate Tribunal (ITAT) on 9 February, 2024, delivered a landmark decision asserting that granting domestic travel agents access to a computer reservation system located abroad does not establish a fixed place
See More
Belarus introduces new 25% tax rate for foreign organizations with permanent establishments (PEs)
On 20 March 2024, the Belarusian Ministry of Taxes and Duties released Letter No. 4-2-21/00850 on March 20, 2024, addressing the tax obligations of foreign entities with permanent establishments (PEs) conducting business in the Republic of Belarus.
See More
Germany: MoF issues updated guidelines on permanent establishment criteria and remote work
On 5 February 2024, the German Ministry of Finance (MoF) issued revised instructions concerning the criteria for a permanent establishment (PE), as commonly outlined in section 12 of the General Tax Code for the purposes of domestic tax law.
See More
Slovenia enacts adjustments to permanent establishment and interest limitation regulations
On 9 February 2024, Slovenia officially released the Act amending the Corporate Income Tax Act (ZDDPO-2T) in the Official Gazette. The provisions outlined in the legislation encompass: Preventing PE status misuse: New rules limit on strategies
See More
Saudi Arabia: ZATCA releases drafts of new income tax and tax procedural laws for public consultation
On 25 October 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued drafts of a new Income Tax Law and Zakat and Tax Procedures Law for public consultation. The public consultation period for comments on the drafts is open until 25
See More
Slovenia: MoF issues a draft bill to amend the corporate income tax law
On 17 October 2023, the Slovenian Ministry of Finance (MoF) issued a draft bill to amend the corporate income tax law. Once adopted by the Slovenian parliament the amendments will apply from 1 January 2024. The following amendments are
See More
Egypt publishes income tax amendment law
On 15 June 2023, the Egyptian Tax Authority published Law No. 30 of 2023 in the Official Gazette amending some provisions of the Income Tax Law No. 91 of 2005. The Law entered into force on 16 June 2023. The key amendments to the Income Tax Law are
See More
Pakistan: Government passes Finance Act 2023
On 26 June 2023, the government of Pakistan published the Finance Act 2023, which included changes to some of the measures that were proposed in the Budget announcement on 9 June 2023. Some notable changes, in addition to those outlined in the
See More
Saudi Arabia: ZATC issues a Circular on the taxation of PE in the context of DTA
On 17 May 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued Circular No. 2303001 regarding the taxation of Permanent Establishments (PEs) in the context of Double Taxation Agreements (DTA). The Circular serves to provide
See More
Belarus updates guidance on the taxation of foreign organizations operating through a PE
On 10 March 2023, the Ministry of Taxes and Duties of Belarus issued Guidance Letter No. No.4-2-21/00759 to clarify the taxation of foreign organizations operating in the territory of the Republic of Belarus through permanent establishments (PEs).
See More
Qatar amends income tax law
On 2 February 2023, Qatar published Law No.11 of 2022 amending several provisions of the Income Tax Law No. 24 of 2018 in the official Gazette. The effective date of the amendments is also 2 February 2023. The amendments are generally effective from
See More
Ireland: Revenue issues guidance on attribution of profits to a branch
On 7 September 2022, the Irish Revenue published an eBrief No. 166/22 on the attribution of profits to a branch. Accordingly, Tax and Duty Manual Part 02-02-04a has been issued to provide an overview and guidance in relation to the attribution of
See More
Austria: MOF Updates Guidance on COVID-19 treaty Issues
On 20 June 2022, the Ministry of Finance published a Circular (no. 2022-0.433.029 of 17 June 2022) clarifying various tax treaty issues that have arisen due to the COVID-19 pandemic, including permanent establishments(PE) and the application of the
See MoreUkraine: SFS clarifies PE rule for non-residents for tax purposes
On 12 October 2021, the Ukrainian State Fiscal Service (SFS) has clarified that a non-resident company considers as a permanent establishment (PE) if the company enters into agreements and carries out economic activities in Ukraine on its own
See MoreTaiwan announces the amendments to the tax treaty rules and PE rules
On 12 August 2021, Taiwan’s Ministry of Finance has announced the amendments to the “Regulations Governing Application of Agreements for the Avoidance of Double Taxation with Respect to Taxes on Income”. The amended regulations have come into
See MoreTanzania: Revenue Authority publishes Finance Act 2021
On 30 June 2021, the Revenue Authority Officially published the Finance Act 2021. Some of the tax measures, which generally applies from 1 July 2021 are given below: Permanent establishment According to Finance Act 2021, the definition of the
See MoreGreece: Tax administration issues a Circular on tax residency and PE rules
On 25 June 2021, the Tax Administration issued a Circular E. 2130 /2021, which includes additional guidelines in relation to the application of domestic law and double tax treaty provisions with respect to tax residency and permanent establishment
See More