Ireland: 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
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 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 MoreCanada: Finance Minister presents Budget 2021
On 19 April 2021, the Finance Minister, Chrystia Freeland, presented Budget 2021, which includes important business tax measures, digital service taxes, limitation of interest deduction, hybrid mismatch arrangements, transfer price cases, mandatory
See MoreOECD: Request for input on proposed changes to commentary on Article 9 of OECD Model
On 29 March 2021 the OECD issued a public discussion draft on proposed changes to the commentary to Article 9 (associated enterprises) of the OECD Model Tax Convention. The amendments are to be included in the next update of the OECD
See MoreMorocco declares maximum interest rate 1.63% on shareholder loans
On 18 March 2021, Morocco has published Ministerial Decree 423.21 in the Official Gazette regarding the reduction of maximum interest rate for loans granted by direct shareholders from 2.23% to 1.63% for FY 2021. Interest expense on loans will
See MoreSerbia: MOF releases arm’s length interest rates for 2021
On 19 March 2021, the Serbian Ministry of Finance has published the Rulebook on Arm’s Length Interest Rates applicable for 2021 that applies on related parties’ loans. Rulebook comes into force on 27 March 2021. Taxpayers can use
See MoreGreece: Tax Authority describes interest deduction limitation rules
On 11 January 2021, the Greek Public Revenue Authority (AADE) published Circular Ε. 2004 of 11 January 2021, which describes the application of the rule of limitation of interest as amended from 1 January 2019. According to the Circular, the
See MoreLuxembourg Parliament approves Bill on the deduction of interest and royalties expenses
On 28 January 2021, the Luxembourg Parliament has approved Bill No. 7547 introducing a non-deductibility of interest or royalties paid to associate enterprises established in countries that are “blacklisted” as being “non-cooperative” for
See MoreSwitzerland declares safe harbor interest rates
The Federal Tax Administration of Switzerland has published two separate circulars regarding safe harbor interest rate limits applicable to shareholder and related party loans in 2021. The rates may vary depend on whether the financing is in Swiss
See MoreLuxembourg: Tax Authorities issues guidance on interest deduction limitation
On 8 January 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 article 168bis of the Luxembourg Income Tax
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