France: Court decides the statute of limitations for recovery of taxes
Recently, the Administrative Court of Montreuil issued a decision regarding the statute of limitations for the recovery of tax claims following a collection notice. The statute of limitations for recovery is 4 years, although this may be extended by
See More
Cyprus: Clarification Bilateral Agreement for exchange of CbC between Cyprus and the USA
On 13 October 2022, the Cyprus tax authority informed all legal entries and their representatives that the bilateral Competent Authority Arrangement (CAA) for the exchange of Country-by-Country (CbC Reports) between Cyprus and the United States of
See More
UK will increase corporation tax rate as planned
On 14 October 2022, the UK government announced that Corporation Tax will increase to 25% (currently 19%) from April 2023 as already legislated for, raising around £18 billion a year and acting as a down payment on its full Medium-Term Fiscal
See More
Norway: Corporate tax proposals for budget 2023
On 6 October 2022, the National budget for 2023 was delivered including following tax proposals related to corporate taxation. Increasing the tax rate from 35.2% to 37.84% on dividends and capital gains effective from 6 October 2022. It is
See More
Mexico: Senate approves BEPS MLI
On 12 October 2022, the Mexican Senate approved the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Mexico signed the MLI on 7 June 2017. Mexico must now deposit its ratification
See More
Colombia: Congress approved Tax Reform Bill in the first debate
On 6 October 2022, the Colombian Congress approved Tax Reform Bill in the first debate. The Bill was presented to Congress on 8 August 2022. After the final approval of the Bill, the changes will become effective as of 1 January 2023. The main tax
See More
Peru: SUNAT updates the list of high-risk tax planning schemes regarding GAAR
On 11 October 2022, the Peruvian Tax Administration (SUNAT) published second version of the list of high-risk tax planning schemes regarding the General Anti-Avoidance Rule (GAAR). The updated list contains the following thirteen tax planning
See More
Belgium notifies TP penalties first time
The Belgian tax authorities have sent out the first penalty notifications for noncompliance to submit transfer pricing (TP) forms. Generally, TP documentation requirements is mandatory for Belgian entities exceeding the respective thresholds and
See More
Netherlands: Tax authority extends one-off payment break for tax debts to 6 months
The Netherlands has extended the provision for a one-off payment break for the repayment of deferred tax debts of Covid-19 pandemic period from up to 3 months to 6 months. The State Secretary for Finance, Taxation and Tax Administration has
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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
See MoreBelgium 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
See More