Serbia: Ministry of Finance release arm’s length interest rates for 2022
On 16 December 2022, the Serbian Ministry of Finance published the Rulebook on arm’s Length interest rates applicable for 2022 that applies to related parties’ loans. The rulebook comes into force on 24 December 2022. Taxpayers can use the
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Sri Lanka removes concessionary tax rates and several exemptions
On 19 December 2022, the Inland Revenue Department (IRD) has published the Inland Revenue (Amendment) Act No. 45 of 2022. The IRD has also issued notices to taxpayers regarding significant tax changes. The changes are effective from 1 January
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Hong Kong welcomes passage of bill on foreign-sourced income exemption regime
On 14 December 2022, the Hong Kong Legislative Council has passed the Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Bill 2022. The bill introduces a new foreign-sourced income exemption (FSIE) regime for passive income
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Greece increases additional deduction for advertising expenses
On 21 December 2022, Greece published Law No. 5005 in the Official Gazette, which extended the application of the 30% special deduction for advertising expenses to the tax year 2023 as well as 2022. In some circumstances, a 100% additional deduction
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Morocco suspends CbC reporting requirement temporarily
On 16 December 2022, the Moroccan tax authority published an announcement, which temporarily suspending the requirement to file a country-by-country (CbC) report for companies that are part of multinational enterprises (MNEs) operating in Morocco
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UK: Consultation on Transfer Pricing Records Regulations 2023
On 21 December 2022 the UK issued for consultation the draft regulations on Transfer Pricing Documentation, inviting comments from interested parties by 31 January 2023. The draft statutory instrument would require multinationals operating in the
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Luxembourg: Parliament approves budget law 2023
On 15 December 2022, the Luxembourg Parliament approved the budget law 2023. There is no major tax reform or an increase in the tax rate in the draft budget law. Most of the measures will apply from 1 January 2023. The budget law sets out the
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Canada releases Fall Economic Statement Implementation Act 2022
On 15 December 2022, Bill C-32, the Fall Economic Statement Implementation Act 2022, received Royal Assent in Canada. Key measures adopted in Bill C-32 to make life more affordable include: Permanently eliminating interest on Canada Student
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Colombia: Congress enacts tax reform law
On 13 December 2022, the Colombian Congress approved Law 2277 of 2022 (tax reform law) which contains changes in the current tax regime. The main tax measures of the Tax Reform Bill are as follows: Corporate Income Tax (CIT) Although the
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Bulgaria: National assembly approves law for implementation of DAC7
On 8 December 2022, the national assembly of Bulgaria approved law on amendments and supplements to the tax and insurance procedural code. The primary objective of the law is to implement the new rules on the exchange of information on income
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Taiwan provides the list of low-tax jurisdictions under CFC rules
On 13 December 2022, the Ministry of Finance of Taiwan issued a press release providing the list of low-tax jurisdictions under controlled foreign company (CFC) rules. The CFC rules will be effective from 1 January 2023 for profit-making enterprises
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UAE publishes new corporate tax law
On 9 December 2022, the UAE Ministry of Finance (MoF) released the Federal Decree-Law No. 47 of 2022 on business taxation to enact a new Corporate Tax Law in the UAE. The new law has been supplemented with Frequently Asked Questions (FAQs). The
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OECD: Tax certainty for Pillar Two rules
On 20 December 2022 the OECD issued a consultation document on providing tax certainty under the Pillar Two GloBE rules. Comments are invited from interested parties by 3 February 2023. The GloBE rules are to be enacted by each jurisdiction into
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OECD: Consultation on GloBE Information Return
On 20 December 2022 the OECD’s Inclusive Framework issued the consultation document Pillar Two – GloBE Information Return, setting out proposals on the information return to be completed by multinationals in relation to the global minimum tax.
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OECD: Draft Multilateral Convention Provisions on Digital Services Taxes under Amount A
On 20 December 2022 the OECD issued for public consultation draft provisions on digital services taxes that would be included in a multilateral convention (MLC) in relation to Pillar One of the two-pillar approach to international taxation. The
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Czech Republic enacts DAC7
On 7 December 2022, the Czech Republic enacted Law No. 373/2022 for implementing into domestic legislation, the EU Directive imposing reporting and exchange of information requirements concerning the activities of certain digital platform operators
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OECD: Safe Harbours and Penalty Relief under Pillar Two
Following the publication of the GloBE model rules there were concerns about the complexity of some of the adjustments to income and taxes required under rules, which could place an unnecessarily large compliance burden on some multinationals. There
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Finland: Tax agency explains the tax changes for 2023
On 13 December 2022, the Finnish tax administration has released an explanation of tax changes for 2023. Some of them are legislative changes proposed by the Government but not yet debated in the parliament. The proposals related to corporate
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