Luxembourg: 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 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 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
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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 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 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 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 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
See MoreFinland 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 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 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 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
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