Finland announces to amend interest deduction limitation rules
On 4 November 2021, the government of Finland has published a proposal to the interest deduction limitation rules. The proposed amendments are particularly relevant for companies that rely on the “balance sheet test” which provides for an
See MoreFinland: Parliament adopts bill to amend cross-border hybrid mismatch rules
On 29 October 2021, the Parliament of Finland has adopted the Bill No.204/2021 to amend cross-border hybrid mismatch rules, implementing the EU anti-avoidance directives. The bill includes following measures to transpose the reverse hybrid mismatch
See MoreGermany publishes court ruling on the arm’s-length interest rate on intercompany loans
On 21 October 2021, the German Ministry of Finance released Tax Court Decision No. IR 4/17(dated 18 May 2021), regarding the calculation of an arm's-length interest rate on intercompany loans. Under the ruling, the interest rate should be based
See MoreNetherlands: Amendments to revise CIT rate proposes for 2022 tax plan
On 5 October 2021, the amendments to the “2020 Tax Plan” were presented to the lower house of Parliament of the Netherlands. Further amendments to the “2022 Tax Plan” were presented on 15 October 2021 to the lower house of Parliament. The
See MoreIreland: Finance Ministry delivers the Budget 2022
On 12 October 2021, the Finance Ministry presented Budget 2022, which covers the following tax measures: The new minimum effective corporation tax rate will be 15%. However, Ireland will continue to offer the 12.5% rate for businesses with
See MoreNetherlands presents Budget for 2022
On 21 September 2021, the Dutch Budget for 2022 was presented. This year, the 2022 tax plan package mainly contains minor changes aimed at improving the tax system. In particular, improvements will be made to existing taxes in the areas of housing,
See MoreIreland: Government publishes Tax Strategy Group Papers prior to Budget 2022
On 16 September 2021, the Finance Department and the Department of Employment Affairs and Social Protection published Tax Strategy Group papers prior to Budget 2022. Some of the changes in the Budget papers are given below: Corporate tax As
See MoreFinland: Ministry of Finance issues budget proposal for 2022
On 9 September 2021, the Ministry of Finance of Finland has released the government’s budget proposal for 2022 including following tax measures. Companies may make an extra deduction of 150% in their taxation for 2022-2027 for research and
See MoreIreland: Revenue updates TP rules for some qualifying companies
On 6 September 2021, the Revenue updated its guidance to assist some qualifying companies in accordance with Section 110 regarding the application of transfer pricing (TP) rules and other issues. Under Section 110, a company be a qualifying one if
See MoreKorea: MOEF proposes Tax Revision Bill 2021
On 26 July 2021, South Korea’s Ministry of Economy and Finance (MOEF) has issued an overview of the proposed Tax Revision Bill 2021 to support new industries and employment, as well as inclusive growth. The Tax Revision Bill 2021 includes the
See MoreLuxembourg issues updated guidance on interest deduction limitation
On 28 July 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 the article 168bis of the Luxembourg Income Tax
See MoreGermany: MOF issues new guidance on transfer pricing
On 14 July 2021, the German Ministry of Finance (MoF) published a decree providing updated administrative principles on transfer Pricing. The new decree replaces several decrees that were passed in the past at transfer prices, in particular the
See MoreKenya enacts Finance Act 2021
On 1 July 2021, Kenya published the Finance Act 2021 in the official gazette. The act was signed into law by the president on 29 June 2021. The act was presented to Parliament by the Kenyan Treasury Cabinet Secretary on 4 May 2021. The act
See MoreIreland: Government declares a second feedback statement on ATAD interest limitation rule
On 2 July 2021, the Finance Minister, Paschal Donohoe TD, launched a second Feedback Statement on transposition of the ATAD interest limitation ratio. The Anti-Tax Avoidance Directive (ATAD) requires Member States to introduce an interest
See MoreIreland: Finance Ministry declares for a feedback statement on ATAD anti-hybrid rule
On 2 July 2021, the Finance Minister, Paschal Donohoe TD, launched a Feedback Statement on the Anti-reverse hybrid rule. The anti-hybrid rules are largely contained in ATAD2, which extended the basic anti-hybrid provisions of the first ATAD and
See MoreLuxembourg: Circular provides updated guidance on interest deduction limitation
On 2 June 2021, the Luxembourg Tax Authorities has published Circular L.I.R. n° 168bis , which clarifies certain aspects of the interest expense deduction limitation rules included in article 168bis of the Luxembourg Income Tax Law (ITL). The
See MorePeru: SUNAT clarifies interest deduction for thin capitalization rules
On 12 May 2021, the Peruvian Tax Administration (SUNAT) has issued Report No. 015-2021-SUNAT / 7T000 (the Guideline)regarding various queries related to the application of the limit for the deduction of interest expenses are answered, referred to
See MoreKenya publishes Finance Bill 2021
On 5 May 2021, the Parliament of Kenya has published the finance bill 2021 providing the following tax measures: Reintroduce the definition of the term ‘‘Control” The definition of the term “control” was deleted with the
See More