Spain: Council of Ministers adopts Royal-Decree implementing the reverse hybrid rules
On 18 October 2022, the Spanish Council of Ministers approved the Royal Decree-Law (RDL) implementing the reverse hybrid rules under the Anti-Tax Avoidance Directive 2017/952 (ATAD-2). The law generally aims to combat tax avoidance as a result of a
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Transfer Pricing Brief: December 2022
Argentina Compliance with BEPS standards: On 8 November 2022, the Argentine Commission on Foreign Affairs accepted a bill to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). See the story in
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South Africa: National treasury releases statement on BEPS MLI
On 1 December 2022, the South African National Treasury publishes a media statement on Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("Multilateral Instrument" or "BEPS MLI"). The Base
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Kazakhstan clarifies tax exemption criteria for dividends from listed securities
Kazakhstan clarifies tax exemption criteria for dividends from listed securities 7 Dec 2022 On 17 November 2022, the Government of Kazakhstan issued Resolution No. 911 clarifying tax exemption criteria for dividends from listed securities. The
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Singapore: IRAS publishes updated e-tax guide on tax exemption
On 1 December 2022, the Inland Revenue Authority of Singapore (IRAS) published an updated e-Tax Guide on tax exemption for Real estate investment trusts and qualifying offshore infrastructure project or asset. The e-Tax Guide describes the scenarios
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Austria plans to expand the application on existing treaties under BEPS MLI
On 30 November 2022, the Austrian Council of Ministers approved the extension of the application on existing tax treaties under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting
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Saudi Arabia: GAZT extends tax penalty relief measures up to 31 May 2023
On 30 November 2022, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) announced the extension of tax penalty relief measures in response to the COVID-19 pandemic. Accordingly, the taxpayers can be exempted from fines and financial penalties
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US: IRS publishes interest rates on overpaid and underpaid tax for Q1 of 2023
On 29 November, the Internal Revenue Service announced that interest rates will increase for the calendar quarter beginning January 1, 2023. For individuals, the rate for overpayments and underpayments will be 7% per year, compounded daily, up
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Portugal: Parliament approves budget for 2023
On 25 November 2022, the Portuguese parliament approved the Budget for 2023. This budget includes the following corporate tax measures: Changes in current tax loss carry forward rules for corporate income tax (CIT). Along with other things, tax
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Ireland proposes windfall profit tax in the energy sector
On 22 November, the Irish Minister for the Environment, Climate and Communications, Eamon Ryan announced measures to address windfall gains in the energy sector through the implementation of Council Regulation (EU) 2022/1854. Elevated wholesale
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Vietnam: MoF publishes guideline for STD fund
On 7 November 2022, the Ministry of Finance (MoF) of Vietnam published a Circular No. 67/2022/TT-BTC which provides a detailed tax obligations guideline for the companies that create and use a science and technology development (STD) fund. As per
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OECD: Consumption tax trends 2022
On 30 November 2022 the OECD released Consumption Tax Trends 2022, an annual publication setting out comparative data on consumption taxes and trends in consumption tax policy in OECD countries. The data indicate that as e-commerce increases the
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OECD: Revenue Statistics 2022
On 30 November 2022 the OECD published Revenue Statistics 2022. The publication sets out the statistics of tax revenue for 2021 which indicate that tax revenues were recovering after the crisis caused by the pandemic. The publication classifies
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Ecuador submits a draft bill in the parliament on tax incentives for audiovisual and energy sectors
On 24 November 2022, the government of Ecuador submitted a draft bill in the National Assembly that provides incentives for audiovisual and energy sectors. The incentives include: A remittance tax exemption on expenditures occurs for carrying
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Ireland explains non-resident corporate landlords within the charge to corporation tax
On 21 November 2022, the Irish Revenue published eBrief No. 199/22 clarifying that corporate landlords are subject to corporation tax rather than income tax on Irish rental income from 1 January 2022. Accordingly, the following Tax and Duty Manuals
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Ghana: Tax measures of 2023 Budget
On 24 November 2022, Ghana’s Finance Minister read the 2023 Budget Statement and Economic Policy in Parliament. The 2023 Budget is focused on resetting economy and restoring macroeconomic stability. Accordingly, the Minister outlined the following
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US: IRS issues guidance related foreign tax credit
On 22 November 2022, the U.S. Internal Revenue Service issued a guidance relating to the foreign tax credit, including guidance with respect to the reattribution asset rule for purposes of allocating and apportioning foreign taxes, the cost recovery
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Italy approves draft Budget for 2023
On 21 November 2022, Italian Council of Ministers approved the State Budget for 2023 along with the multi-year budget for 2023 to 2025. The budget increasing the tax credits for the purchase of natural gas and electricity through March 2023 and
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