Sweden: 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
See MoreAustralia: ATO releases final guidance on related party loan
On 10 December 2020, the Australian Taxation Office (ATO) issued final transfer pricing guidance on interest-free loans between related parties, in “Schedule 3 – Interest-free loans” to the ATO’s financing Practical Compliance Guideline
See MorePeru: Tax Administration issues report on interest deduction limitations
On 10 November 2020, the Peruvian Tax Administration (SUNAT) has published Report No. 093-2020-SUNAT/7T0000 on its website, which clarifies the interest deduction limitations rules. Through the Report, SUNAT analyzes the application of the
See MoreVietnam: MoF issues new transfer pricing Decree
On 5 November 2020, the Vietnamese Ministry of Finance (MoF) has issued new transfer pricing Decree No. 132/2020/ND-CP. The new Decree replaces the existing Transfer Pricing (TP) regulations (Decree No. 20/2017/ND-CP) and provides the following new
See MoreIreland: Finance Minister publishes Finance Bill 2020
On 22 October 2020, the Finance Minister, Paschal Donohoe TD, published Finance Bill 2020 following Cabinet approval at the Government meeting. The Bill underpins the Government’s support for the economy in the face of Covid-19 pandemic and the
See MoreCosta Rica issues resolution on request for increased interest deduction limits
On October 15, 2020, Costa Rica published Resolution DGT-R-0032-2020, which outlines the application process for the taxpayer to increase the maximum deduction limit for net interest expense. The restriction on the deduction of interest expense was
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