Kenya: Tax measures in finance act 2023
On 3 July 2023, the Kenya Revenue Authority published the Finance Act 2023, following its presidential assent on 26 June 2023. The act includes the following notable provisions related to corporate income taxation. Digital assets
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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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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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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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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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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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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
See MoreAustralia: 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
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
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 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
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