Germany: CJEU has issued a decision on sanctions for non-compliance with TP documentation requirements
On 13 October 2022, the Court of Justice of the European Union (CJEU) ruled in case: C-431/21 on sanctions for non-compliance with transfer pricing (TP) documentation requirements. Under German law, there is a rebuttable presumption that the
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Malaysia: Corporate tax proposals in budget 2023
On 7 October 2022, the Finance Minister, YB Senator Tengku Dato’ Sri Zafrul Tengku Abdul Aziz has announced the nation’s 2023 Budget. The budget includes the following tax proposals related to corporate taxation. Reduced the income tax rate
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OECD: Consultation on Administration and Certainty Aspects of Amount A of Pillar One
On 6 October 2022 the OECD published for public consultation a document with the title Progress Report on the Administration and Tax Certainty Aspects of Pillar One. Comments are invited from interested parties by 11 November 2022. Administration
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World Tax Brief: October 2022
Angola Withholding tax rate-Others: On 22 August 2022, Angola published Law no. 27/22 in the Official Gazette amending the Corporate Income Tax Code. Accordingly, the withholding tax (WHT) rate on services paid to non-residents has been
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South Africa: SARS publishes updated interest rate tables
On 13 September 2022, the South African Revenue Service (SARS) issued updated interest rate tables. The South African Reserve Bank changed the “repo rate” on 22 September 2022, effective on 1 October 2022. The tables of interest rates are
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Mongolia signs MLI to implement tax treaty related BEPS measures
On 6 October 2022, Mongolia signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, at a signing ceremony held in Paris at the 14th meeting of the Inclusive Framework on BEPS. Mongolia
See MoreMalaysia publishes guidelines on tax treatment of income received from abroad
On 29 September 2022, the Malaysian Inland Revenue Board published its guidelines on tax treatment in relation to income which is received from abroad. The objective of the guideline is to explain the tax treatment of foreign income received in
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OECD: Inclusive Framework Progress Report
On 4 October 2022 the OECD released a document with the title OECD/G20 Inclusive Framework on BEPS: Progress Report September 2021-September 2022. The progress report summarises developments in the work of the Inclusive Framework on base erosion and
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Belgium declares filing and prefiling requests for FY 2023
On 30 September 2022, the Belgian Ruling Commission announced filing and prefiling requests related to the innovation income deduction and transfer pricing. According to the announcement, all prefiling requests related to corporate income tax
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OECD: Plenary Meeting of the Inclusive Framework on BEPS
On 6 October 2022 the 14th plenary meeting of the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) was attended by delegates from more than 135 countries and jurisdictions. The meeting heard that substantial progress has been
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Germany: Government publishes a draft bill for public CbC reporting
On 30 September 2022, the German Federal Ministry of Justice published draft legislation for the implementation of EU public country-by-country (CbC) reporting Directive 2021/2101 as regards the disclosure of income tax information by certain
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Transfer Pricing Brief: October 2022
Armenia Compliance with BEPS standards: On 14 September 2022, the Armenian Parliament (National Assembly) approved draft Bill No. K-294 for ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
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Lithuania: MoF announces reduced interest rate on deferred tax payment
On 27 September 2022, the Lithuanian Ministry of Finance (MoF) published the Order No.1K-325 providing a reduced interest rate on deferred payment (tax loan agreements) of taxes and fines for administrative offenses. Usually, it is equal to 0.01%
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Puerto Rico extends tax returns and payment deadline due to Hurricane Fiona
On 27 September 2022, the Puerto Rico Treasury Department (PRTD) issued Administrative Determination No. 22-08 extending the due date for income tax returns and tax payments due to Hurricane Fiona. The PRTD extends the tax returns deadline until
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OECD: Digital Services to Support SMEs
During the plenary meeting of the OECD’s Forum on Tax Administration (FTA) held from 28 to 30 September 2022, a report was released with the title: Digital Services: Supporting SMEs to Get Tax Right. The report is one of a series that are planned,
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UK: Growth Plan to address high energy costs and inflation
On 23 September 2022 the UK government announced a series of measures aiming to boost economic growth. Corporation tax The planned rise in corporation tax is cancelled, so the rate of corporation tax will remain at 19%. The Annual
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OECD: Bilateral Advance Pricing Agreement Manual
The Bilateral Advance Pricing Agreement (BAPA) Manual issued by the Forum on Tax Administration (FTA) on 28 September 2022 was formulated after considering answers to surveys of jurisdictions, competent authorities and the advisory group Business at
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OECD: Tax Administration 3.0 and the Digital Identification of Taxpayers
During the plenary meeting of the OECD’s Forum on Tax Administration (FTA) held from 28 to 30 September, a report was released looking at the state of maturity of the use of digital identities within tax administrations. This was one of a number
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