Spain 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).
See MoreBulgaria approves amendments to the CIT Act
On 20 January 2022, the Bulgarian Parliament passed the draft law amending and supplementing the Corporate Income Tax Act (CITA). The draft law provides for the implementation of the reverse hybrid mismatch rules of the EU Anti-Tax Avoidance
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South Korea enacts tax revision bill for 2022
In December 2021, South Korea has enacted a tax revision bill for 2022 which was passed by Korea’s National Assembly on 2 December 2021. The tax revision bill is generally effective from fiscal years beginning on or after 1 January 2022. The
See MoreLithuania adopts important tax law changes
On 7 December 2021, the Lithuanian Parliament adopted several important amendments to the Law (No.IX-675) on the Corporate Income Tax of the Republic of Lithuania. The law proposed the following measures: Effective from 1 July 2022, the
See MoreCroatia: Finance Ministry decides new interest rate between related parties
The Ministry of Finance announced a new interest rate of 2.68% on loans between related parties for 2022 before the beginning of the tax period in which it is applied. This means that interest is calculated at the rate of 2.68% of the minimum
See MorePeru: SUNAT issues Decree on interest deduction limitation rules
On 30 December 2021, the Peruvian Tax Administration (SUNAT) has issued Supreme Decree 402-2021-EF in the Official Gazette clarifying the regulations for interest deduction limitation rules. From 1 January 2021, interest exceeding 30% of EBITDA
See MoreSaudi Arabia: ZATCA releases the third edition of transfer pricing guidelines
In November 2021, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) released the third edition of Transfer Pricing Guidelines in English. The first edition and second edition were released in March 2019 and May 2020 respectively. These
See MoreIreland: President signs Finance Bill 2021 into Law
On 21 December 2021, President signed the 2021 Finance Bill into Finance Act 2021, which provides for the implementation of the 2022 Budget measures as well as some necessary anti-avoidance measures and technical changes to the tax code. Some of
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 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: MOF publish clarification guidance for TP purposes
On 18 November 2021, the Russian Ministry of Finance (MoF) published a Guidance Letter No. 03-03-07/85525 clarifying that a loan is considered a controlled debt for Transfer Pricing (TP) purposes if it is granted to a Russian company by a third
See MoreSouth Africa: Parliament tables 2021 Tax Bills
On 11 November 2021, Tax Bills 2021 (Taxation Laws Amendment Bill (TLAB), Tax Administration Laws Amendment Bill (TALAB), Rates and Monetary Amounts and Amendment of Revenue Laws Bill (Rates Bill)) were tabled in the Parliament. The National
See MoreGermany publishes court decisions concerning the intercompany loans
On 4 November 2021, The German Ministry of Finance (MoF) published Tax Court Decision No. IR 32/17of 9 June 2021, on the taxation of corporate income based on unsecured loans to foreign related companies. In that case, a domestic company granted
See MoreAustralia amends guideline on simplified transfer pricing record-keeping options
On 11 November 2021, the Australian Taxation Office (ATO) amended its practical compliance guideline on simplified transfer pricing record-keeping options to provide maximum and minimum interest rates for low-level inbound and outbound
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