OECD: Peer Review Report on Harmful Tax Practices
On 14 December 2021 the OECD published a report entitled: Harmful Tax Practices – 2020 Peer Review Reports on the Exchange of Information on Tax Rulings. The standard under Action 5 of the OECD/G20 action plan on base erosion and profit
See MoreFrance: Tax Authority publishes a guide regarding the application of anti-hybrid rules
On 15 December 2021, the Tax Authority published a guide, which covers the measures implemented in compliance with the EU Anti-Tax Avoidance Directive as amended (ATAD1 and ATAD2) as part of the Finance Law for 2020. The hybrid mismatch measures
See MoreGreece: Finance Ministry highlights tax measures on 2022 Budget
On 17 December 2021, the Finance Ministry announced an overview of tax measures on the 2022 Budget. Some of the approved tax measures are given below: The corporate income tax rate is reduced from 24% to 22% for legal entities and legal entities
See MoreOECD: Revenue Statistics in Africa 2021
On 15 December 2021 the OECD published Revenue Statistics in Africa 2021, covering 30 African countries that account for 75% of Africa’s GDP. The publication is a joint initiative of the African Tax Administration Forum (ATAF), the African Union
See MoreSouth Africa: SARS opens a public consultation for an APA program
On 10 December 2021, the South African Revenue Service (SARS) made an announcement for inviting public comments for a model and draft legislation regarding Advance Pricing Agreement (APA) system until the end of January 2022. The draft model is
See MoreAustralia: ATO issued PCG 2021/5 on imported hybrid mismatch rule
On 16 December 2021, the Australian Taxation Office (ATO) issued Practical Compliance Guideline 2021/5 on imported hybrid mismatch rule – ATO’s compliance approach (PCG 2021/5) relating to a practical administrative approach to the imported
See MoreRussia increases the interest rate from December 2021
On 17 December 2021, the Russian Central Bank has announced the decision to increase the key rate from 5% to 8.5% with effect from 20 December 2021. The new rate applies from The CBR's key interest rate is used for the purposes of calculating
See MoreUK: HMRC updates late payment interest rates
On 17 December 2021, the UK HMRC has announced the revision of late payment interest rates following the base rate increase to 0.25% by the Bank of England. The Bank of England Monetary Policy Committee voted on 16 December 2021 to increase the
See MoreUK: LOB Clause of US-UK treaty does not restrict unilateral foreign tax credit
Aozora GMAC Investments Limited, resident in the UK, was a subsidiary of a Japanese bank. The taxpayer made a loan to its subsidiaries in the US. Article 11(1) of the US-UK double tax treaty provided for exclusive taxation of the interest income
See MoreArmenia increases the interest rate from December 2021
On 14 December 2021, the Armenian Central Bank has announced the decision to increase the key rate from 7.25% to 7.75% with effect from December 2021. The interest rate of the Central Bank is used for the purposes of calculating interest
See MoreLuxembourg updates the list of jurisdictions for exchanging CbC reports
On 13 December 2021, the Luxembourg Ministry of Finance published Grand-Ducal Regulation of 9 December 2021 in the Official Gazette amending Grand-Ducal Regulation of 13 February 2018. The Regulation updates the list of
See MoreUK: Summary of responses to consultation on VAT exemption for land
On 30 November 2021 the UK government published a summary of responses to the consultation on aspects of the VAT exemption for land and the option to tax. A consultation paper in May 2021, asked for evidence to assess potential options for
See MoreFinland: Parliament adopts the law on transfer pricing adjustment
On 9 December 2021, the Finnish Parliament has approved the amendment to the transfer pricing adjustment provision, (VML Section 31) of the Tax Procedure Act (VML). On 16 December 2021, the President signed the law, the amendment will take effect
See MoreUK: Improving the Tax Administration Framework
On 30 November 2021 the UK government published a summary of responses to the call for evidence entitled The Tax Administration Framework: Building a 21st Century Tax System. The call for evidence had been issued in March 2021. The government
See MoreUK: Amendments to Securitisation Tax Regime
On 30 November 2021 the UK government published a summary of responses to the consultation on the securitisation tax regime. The consultation paper issued on 23 March 2021 contained suggestions on the reform of the taxation of securitisation
See MoreNigeria: President submits Finance Bill 2022 to Senate
On 7 December 2021, the President, Muhammadu Buhari, transmitted the Finance Bill 2021 through a letter to the Senate for consideration. In the letter, the President explained that the Finance Bill seeks to support the implementation of the 2022
See MorePanama amends CbC reporting penalties
On 11 November 2021, Panama published Law No. 254 in the Official Gazette No. 29413-A, which amends the legislation on international tax transparency and the prevention of money laundering, and the financing of terrorism. The significant
See MoreUK: Compliance Experience of Large Business
On 30 November 2021 the UK government published its response to the review of large businesses’ experiences of UK tax administration, taking into account the feedback received from stakeholders. The review, first announced in the Spring Budget
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