Australia: Budget proposal for FY 2022-23
On 25 October 2022, the Australian Treasurer Jim Chalmers delivered the Federal Budget for fiscal year 2022-23. The key tax measures are as follows: Thin capitalization The Budget amended the thin capitalization rules to limit debt deductions
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Ireland: Government publishes Finance Bill 2022
On 20 Oct 2022, Ireland’s Minister for Finance Paschal Donohoe published the Finance Bill 2022 as part of the Irish budget. The Finance Bill contains new tax measures that were not included in the budget presented in September 2022. The main tax
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Luxembourg: Finance Minister presents draft budget law 2023 to the Parliament
On 12 October 2020, Luxembourg’s Finance Minister presented the draft budget law 2023 to the Parliament. There are no measures regarding major tax reform or an increase in the tax rate in the draft budget law. The draft budget law sets out the
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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Netherlands publishes new transfer pricing decree
On 1 July 2022, the Netherlands Ministry of Finance issued Decree No. 2022-0000139020 related to the application of the arm's length principle and the OECD transfer pricing guidelines. The New Decree replaces the previous transfer pricing (TP)
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Ireland: Revenue issues eBrief on anti-hybrid rules guidance
On 29 June 2022, the Irish Revenue published an eBrief No. 137/22 to announce a manual to update the guidance on anti-hybrid rules. Accordingly, Tax and Duty Manual Part 35C-00-01 - Guidance on the Anti-hybrid rules - has been updated for
See MoreGreece enacts ATAD’s reverse hybrid rule
On 30 June 2022, the government of Greece enacted legislation implementing ATAD's reverse hybrid rule with retroactive effect from 1 January 2022. The rule does not apply to collective investment vehicles. The new rule applies to situations where
See MoreKenya: President gives assent to the finance act 2022
On 21 June 2022, Kenya’s President has given his assent to the Finance Act 2022 which was presented to the Parliament on 13 April 2022. The act contains following tax measures mostly take effect on 1 July 2022. The Bill proposed to introduce
See MoreCanada: Government invites feedbacks on draft legislation regarding hybrid mismatches
On 29 April 2022, the Finance Department published a draft legislation proposals that would address hybrid mismatch arrangements, which are used primarily by multinational enterprises to avoid paying their fair share of tax, as committed to in
See MoreGreece: Government introduces new rules for interest deduction restriction
On 28 March 2022, Government published Law No. 4916/2022, which establishes new group escape rules for the 30% of EBITDA interest deduction restriction. The new group scape rule was made optional when the Greek interest restriction rules were
See MoreLuxembourg: Tax Authority updates guidance on interest deduction limitation
On 25 March 2022, the Luxembourg Tax Authority updated 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 Law (ITL).
See MoreLuxembourg: MOF introduces a new Bill to the Parliament on ATAD
On 9 March 2022, the Luxembourg Ministry of Finance introduced a new Bill 7974 to the Parliament to amend the current interest deduction limitation rules under the EU Anti-Tax Avoidance Directive (ATAD). The Bill excludes ‘EU
See MoreCanada: Finance Department invites public comments on draft tax proposals
On 4 February 2022, the Canadian federal government released draft legislation to implement a variety of proposed tax measures including the new "Excessive Interest and Financing Expenses Limitation" (EIFE Limit) first announced in the April 2021
See MoreSpain adopts ATAD2 anti-hybrid rules
On 9 March 2022, Spanish government amended the Corporate Income Tax (CIT) law and the Non-Resident Income Tax (NRIT) law to address hybrid mismatches. The purpose of these amendments is to enact into Spanish domestic law the anti-hybrid rules
See MoreCanada: Public comments of draft tax Proposals for Certain Budget 2021
On 7 February 2022, the Department of Finance released for public comment a set of draft legislative proposals to implement previously announced and other tax measures. Specifically, the proposals would implement Budget 2021 measures to: Allow
See MoreItaly: Final guidance on hybrid mismatches rules
On 26 January 2022, the Italian Revenue Agency (IRA) has declared the finalization of Circular No. 2/2022. The circular clarifies the hybrid mismatch rules that has introduced as part of the Decree No. 142 of 2018, which transposed the measures
See MoreMalaysia: IRBM releases rules amending the restriction on deductibility of interest
On 31 January 2022, Inland Revenue Board of Malaysia (IRBM) published the Income Tax (Restriction on Deductibility of Interest) (Amendment) Rules 2022, amending the original rules published in 2019. The rules amend the definition of
See MoreCyprus: Tax department issues a new FAQs section on transfer pricing
On 24 January 2022, the Cyprus Tax Department published a new “Frequently Asked Questions (FAQs)” section on its website on Transfer Pricing (TP). The FAQs relate to the Interpretative Circular 3 issued on 30 June 2017 (Back-to-Back Circular).
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