China: BEPS MLI in Force
On 1 September 2022, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for China. With regard to the double taxation agreements between China and other
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Taiwan: MOF exempts provisional income tax payments from January to June 2022
Recently, the Ministry of Finance of Taiwan provides an exemption on provisional income tax payments for the period January to June 2022. The exemption is provided for provisional income tax returns in September 2022 for companies affected by the
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IMF Report Considers Austria’s Fiscal Position
On 2 September 2022 the IMF published a report following the conclusion of discussions with Austria under Article IV of the IMF’s articles of agreement. The IMF report notes that Austria’s economy has recovered strongly from the problems
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OECD: Impact of Population Ageing on Government Revenue
On 30 August 2022 the OECD published a Fiscal Federalism paper dealing with the effect of population ageing on tax revenue across all levels of government. The study is part of a larger project examining the fiscal challenges of population ageing.
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Angola reduces WHT rate on services for nonresident legal entities
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 reduced to 6.5% from 15%. The rate is effective
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US: Sixth Circuit affirms taxpayer not liable for penalty upon cancellation of APAs
On 25 August 2022, the U.S. Court of Appeals for the Sixth Circuit affirmed in part and reversed in part a decision of the U.S. tax court regarding the transfer pricing case of Eaton Corp. v. Commissioner. Facts of the case Eaton Corporation
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El Salvador: Legislative Assembly adopts tax amnesty program
On 24 August 2022, the Legislative Assembly of El Salvador approved tax amnesty program that allows taxpayers voluntarily come forward, accurately declare their income and pay any undeclared or underreported taxes. The El Salvador tax authorities
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US: IRS provides broad-based penalty relief for certain 2019 and 2020 returns
To help struggling taxpayers affected by the COVID-19 pandemic, on 24 August 2022, the Internal Revenue Service issued Notice 2022-36, which provides penalty relief to most people and businesses who file certain 2019 or 2020 returns late. The relief
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New Zealand extends R&D tax incentive due dates
On 26 Aug 2022, New Zealand’s Inland Revenue (IR) issued research and development (R&D) tax incentive updates due to the ongoing COVID-19 pandemic. The IR provides details on R&D tax incentive extensions, changes to claiming supporting
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Russia proposes to raise tax evasion thresholds
On 18 August 2022, the government launched a consultation on a proposal to raise the thresholds for tax evasion by legal entities. Accordingly, the criminal liability thresholds are amended as follows: The proposed threshold for large-scale tax
See MoreSlovak Republic approves draft bill to amend transfer pricing rules
The government of the Slovak Republic has approved the draft law amending the Income Tax Act and the Act on Tax Administration. The amendments include following changes: implementation of rules on restriction of interest deduction in accordance
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Paraguay updates list of low-tax Jurisdictions
On 24 August 2022, the Paraguayan tax authority (SET) issued General Resolution No. 118/2022, concerning the Transfer Pricing Technical Study (ETPT) and a list of low-tax jurisdictions. The amended list of low-tax jurisdictions are
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Greece introduces new tax incentives
On 29 July 2022, Greece enacted legislation (Bill 4957/2022) that provides new research and development (R&D) tax incentives for companies. The law includes the following measures: -Provision of a deduction for R&D-related business
See MoreUS: Tax court issues an opinion regarding transfer pricing method
On 18 August 2022, the U.S. Tax Court issued an opinion on the transfer pricing case of Medtronic, Inc. v. Commissioner, T.C.  Memo 2022-85. Facts of the case Medtronic US is the parent company of a global medical device company that
See MoreUS Inflation Reduction Act includes 15% corporate minimum tax on book income
On 16 August 2022, the President of the United States (US), Joe Biden, signed the Inflation Reduction Act (the Act) into law providing a 15% corporate alternative minimum tax (CAMT) based on book income. The Corporate Alternative Minimum Tax (CAMT)
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Argentina issues resolution introducing exceptional tax prepayment obligation
On 16 August 2022, Argentine tax authority (AFIP) published General Resolution No. 5248/2022, requiring a one-time tax payment for certain large companies that benefitted from deducting losses due to the coronavirus pandemic and ongoing
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Switzerland: Public Consultation on Minimum Corporate Tax Rules
On 17 August 2022 Switzerland launched a consultation on an ordinance to legislate for important elements in the OECD’s global minimum corporate tax under Pillar 2 of the international tax measures. The draft legislation would introduce a Swiss
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Singapore amends regulations on CbC reporting agreements
On 11 August 2022, the Ministry of Finance published an amended Regulation No. S 669 on Country-by-Country (CbC) Reporting Agreements in the Official Gazette. The Regulation includes the following changes: Certain companies are required to file
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