Australia: New legislation proposes amendments to interest limitation rule
Legislation has been introduced in Parliament, suggesting amendment to the interest limitation or thin capitalization rules, which is closely align with the exposure draft legislation. If approved, these rules will be effective for income years
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US: IRS publishes practice units on interest expense limitations
On 16 May 2023, the IRS Large Business and International (LB&I) division issued two practice units in relation to interest expense limitations for related party loans. Interest Expense Limitation on Related Foreign Party Loans Under IRC
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Uganda: Minister of Finance presents Budget for 2023/2024 to the Parliament
On June 15, 2023, the Ugandan Minister of Finance, Planning, and Economic Development, Mr. Â Matia Kasaija, presented the budget for financial year 2023/2024 to the Parliament. On that day, Income Tax (Amendment) Bill 2023 was also passed which was
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Luxembourg: Tax Authority publishes guidance on reverse hybrid rules
On 9 June 2023, the Luxembourg Tax Authority published Circular L.I.R. n° 168quater providing guidance on reverse hybrid mismatch regulations. The Circular aims to provide further clarity on various aspects, including the tax classification of
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Spain releases a law introducing new interest deduction limitation rules
On 25 May 2023, Spain published Law 13/2023 in the Official Gazette, which introduces new interest deduction limitation rules in line with the EU Anti-Tax Avoidance Directive (ATAD). Spain's current rules limiting interest deduction were deemed
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UAE clarifies interest deduction rules
On 23 May 2023, the United Arab Emirates (UAE) Ministry of Finance (MoF) published Decision No. 126 of 2023Â on the general rules for limiting the deduction of interest for corporate tax purposes. To determine the deductible interest from taxable
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OECD: Consultation Document on Transfer Pricing for Minerals
On 10 May 2023 the OECD published a consultation document with the title Determining the price of minerals: A Transfer Pricing Framework. This is a draft toolkit to support developing countries in combating base erosion and profit shifting relating
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Norway: MoF launches public consultation proposing to change interest limitation rules
On 12 April 2023, the Norwegian Ministry of Finance launched a public consultation providing a proposal to change the interest limitation rules, which generally limit the deduction of interest expenses for related parties that exceed 25% of EBITDA
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Australia releases exposure draft bill on new thin cap rules
On 16 March 2023, the Australian Treasury issued the Exposure Draft on the earnings before interest, taxes, depreciation, and amortization interest limitation rules (EBITDA). Consultation closes on 13 April 2023. The proposal to change the
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Cyprus: Tax department issues additional FAQs on TPD rules
On 14 March 2023, the Tax Department of Cyprus has issued three additional questions to its Frequently Asked Questions (FAQs) section, with respect to transfer pricing. The additional questions are summarized below: How is the EUR 750,000
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Poland: MoF publishes base interest rates for transfer pricing purpose
On 23 December 2022, the Polish Ministry of Finance published a notice in the official gazette, establishing base interest rates and margin rates for the purposes of transfer pricing for individual and corporate income taxes. The notice specifies
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Belgium amends guidance on interest deduction rule
On 12 January 2023, Belgium issued Circular 2023/C/8, which provides instructions on the application of the 30% of EBITDA interest deduction limitation starting from 1 January 2019, in line with the EU Anti-Tax Avoidance Directive (ATAD). A summary
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Singapore: IRAS updates TP Guidelines on indicative margin for related-party loans
On 3 January 2023, the Inland Revenue Authority of Singapore (IRAS) published updated transfer pricing (TP) guidelines on indicative margin for related-party loans. IRAS publishes the indicative margin at the beginning of each calendar year. The
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Ireland: President signs the Finance Bill 2022 into Law
On 15 December 2022, Michael D. Higgins, the President of Ireland signed the Finance Bill 2022 into Law. The Finance Act contains new tax measures including changes in corporate income tax and transfer pricing related measures. The main tax measures
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Serbia: Ministry of Finance release arm’s length interest rates for 2022
On 16 December 2022, the Serbian Ministry of Finance published the Rulebook on arm’s Length interest rates applicable for 2022 that applies to related parties’ loans. The rulebook comes into force on 24 December 2022. Taxpayers can use the
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Luxembourg: Parliament approves budget law 2023
On 15 December 2022, the Luxembourg Parliament approved the budget law 2023. There is no major tax reform or an increase in the tax rate in the draft budget law. Most of the measures will apply from 1 January 2023. The budget law sets out the
See MoreSpain: Council of Ministers adopts Royal-Decree implementing the reverse hybrid rules
On 18 October 2022, the Spanish Council of Ministers approved the Royal Decree-Law (RDL) implementing the reverse hybrid rules under the Anti-Tax Avoidance Directive 2017/952 (ATAD-2). The law generally aims to combat tax avoidance as a result of a
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Australia: ATO releases updated interest rate for simplified transfer pricing record keeping options for loans
On 17 November 2022, the Australian Taxation Office (ATO) published an updated version of Practical Compliance Guideline (PCG) 2017/2 related to the eligibility criteria for applying simplified transfer pricing record keeping options for low level
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