Slovenia: MoF proposes several amendments to tax changes
On 16 April 2021, the Slovenian Ministry of Finance (MoF) has proposed several amendments to tax changes including the Bill on Amendments to the Value Added Tax (VAT) Act, the Bill on Amendments to the Corporate Income Tax Act, and the Bill on
See MoreCanada: Finance Minister presents Budget 2021
On 19 April 2021, the Finance Minister, Chrystia Freeland, presented Budget 2021, which includes important business tax measures, digital service taxes, limitation of interest deduction, hybrid mismatch arrangements, transfer price cases, mandatory
See MoreOECD: Request for input on proposed changes to commentary on Article 9 of OECD Model
On 29 March 2021 the OECD issued a public discussion draft on proposed changes to the commentary to Article 9 (associated enterprises) of the OECD Model Tax Convention. The amendments are to be included in the next update of the OECD
See MoreIreland: Revenue publishes an eBrief to update guidance on anti-hybrid rules
On 29 March 2021, the Irish Revenue published an eBrief No. 068/21 to announce a manual to update the guidance on anti-hybrid rules. On the similar day, the Revenue also published a Tax and Duty Manual, which provides guidance on the anti-hybrid
See MoreMorocco declares maximum interest rate 1.63% on shareholder loans
On 18 March 2021, Morocco has published Ministerial Decree 423.21 in the Official Gazette regarding the reduction of maximum interest rate for loans granted by direct shareholders from 2.23% to 1.63% for FY 2021. Interest expense on loans will
See MoreSweden: Parliament accepts Bill to implement EU ATAD reverse hybrid mismatches
On 16 March 2021, the Swedish Parliament (Riksdag) has accepted Bill No. 2020/21:111 to implement EU Anti-Tax Avoidance Directive (ATAD) reverse hybrid mismatches. In this bill, it is proposed that rules be introduced regarding the tax treatment
See MoreSerbia: MOF releases arm’s length interest rates for 2021
On 19 March 2021, the Serbian Ministry of Finance has published the Rulebook on Arm’s Length Interest Rates applicable for 2021 that applies on related parties’ loans. Rulebook comes into force on 27 March 2021. Taxpayers can use
See MoreCroatia: Government fixes related party interest rate for 2021
The Croatian Government has changed the arm’s length interest rate from 3.42% per annum to 3% per annum regarding loans between related parties for the year 2021. This rate is effective from 1st January 2021 and applies for loans between resident
See MoreGreece: Tax Authority describes interest deduction limitation rules
On 11 January 2021, the Greek Public Revenue Authority (AADE) published Circular Ε. 2004 of 11 January 2021, which describes the application of the rule of limitation of interest as amended from 1 January 2019. According to the Circular, the
See MoreLuxembourg Parliament approves Bill on the deduction of interest and royalties expenses
On 28 January 2021, the Luxembourg Parliament has approved Bill No. 7547 introducing a non-deductibility of interest or royalties paid to associate enterprises established in countries that are “blacklisted” as being “non-cooperative” for
See MoreSwitzerland declares safe harbor interest rates
The Federal Tax Administration of Switzerland has published two separate circulars regarding safe harbor interest rate limits applicable to shareholder and related party loans in 2021. The rates may vary depend on whether the financing is in Swiss
See MoreLuxembourg: Tax Authorities issues guidance on interest deduction limitation
On 8 January 2021, the Luxembourg Tax Authorities has published Circular L.I.R. n° 168bis/1 (French), which clarifies certain aspects of the interest expense deduction limitation rules included in article 168bis of the Luxembourg Income Tax
See MoreSpain publishes state budget bill for fiscal year 2021
On 31 December 2020, Spain’s State Budget Bill for Fiscal Year (FY) 2021 (the Budget Bill) was published in the Spanish Official Gazette after its prior approval by the Spanish Congress and Senate. The main corporate tax measures are summarized
See MoreIreland: President signs the Finance Bill 2020 into Law
On 19 December 2020, the President signed the Finance Bill 2020 into Law, which underpins the Government’s support for the economy in the face of Covid-19 pandemic and the ongoing threat of a no-deal Brexit. The Finance Act 2020 provisions
See MoreSingapore updates indicative margins for related party loans
The Inland Revenue Authority of Singapore (IRAS) has published updated indicative margins for related party loans. IRAS has introduced an indicative margin which taxpayers can apply on each related party loan not exceeding S$15 million as tabulated
See MoreIreland: Finance Minister publishes a feedback on ATAD interest limitation rule
On 23 December 2020, the Finance Department published feedback statement, which considers the final ATAD measure, an Interest Limitation Rule, which will also be implemented in Finance Bill 2021. In Ireland, the general anti-abuse rule (GAAR) met
See MoreSweden: Parliament approved Budget for 2021
On 17 December 2020, the Swedish Parliament (Riksdag) has approved Budget for fiscal year 2021. The Budget includes the following key tax measures: Temporary tax reduction of 3.9% of the acquisition value of machinery and equipment
See MoreAustria: Parliament approves winter package due to COVID-19 pandemic
On 17 December 2020, the Parliament approved the COVID-19 Tax Measures Act. Recently, the Ministry of Finance has announced the draft winter package on tax measures for the coronavirus outbreak. The package includes the measures to introduce the
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