Austria implements DAC7 into domestic law
On 19 July 2022, Austria published the Tax Amendment Act 2022 in the Official Gazette. Accordingly, Austria implements new reporting obligations Council Directive (EU) 2021/514 for digital platform operators (DAC7) into domestic law. The new rules
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Azerbaijan approves law on joining BEPS inclusive framework
On 26 October 2022, the President of the Republic of Azerbaijan published a law ratifying the Inclusive Framework on Base Erosion and Profit Shifting (BEPS), which was approved by the President on 11 October 2022. The form of exchange of letters
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Sweden: Tax Agency Clarifies guideline on the CbC reporting
On 26 October 2022, the Swedish Tax Agency clarified the guideline for the country-by-country (CbC) reporting followed by the OECD. This includes the following clarifications related to guidance provided by OECD: (i) guidance on when positive
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Australia: 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
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Hong Kong: Block Extension Scheme for Lodgement of 2021/22 Tax Returns
On 19 October 2022, the Hong Kong Inland Revenue Department (IRD) issued a Circular Letter extending the lodgement of 2021/22 tax returns to 30 November 2022. Recognising the genuine difficulties being experienced by businesses and practitioners
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South Africa introduces draft interpretation on definition of “associated enterprises”
On 14 October 2022, the South African Revenue Service (SARS) published a draft interpretation note on the definition of "associated enterprise" for public comment. This draft note provides guidance on the interpretation and application of the
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Israel gazettes amendments to transfer pricing regulations
On 22 September 2022, the Israeli Official Gazette published the Income Tax Regulations 2022, amending the Income Tax Ordinance, which adopted on 30 June 2022 for the introduction of the three-tiered transfer pricing documentation requirements of
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Romania gazettes public CbC reporting directive
On 7 September 2022, the Romanian Official Gazette published the regulations to implement the EU Public country-by-country (CbC) Reporting Directive. The Directive requires qualifying multinational companies operating business in the EU to publicly
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Luxembourg: Finance Minister presents draft budget law 2023 to the Parliament
On 12 October 2020, Luxembourg’s Finance Minister presented the draft budget law 2023 to the Parliament. There are no measures regarding major tax reform or an increase in the tax rate in the draft budget law. The draft budget law sets out the
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Cyprus: Clarification Bilateral Agreement for exchange of CbC between Cyprus and the USA
On 13 October 2022, the Cyprus tax authority informed all legal entries and their representatives that the bilateral Competent Authority Arrangement (CAA) for the exchange of Country-by-Country (CbC Reports) between Cyprus and the United States of
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UK will increase corporation tax rate as planned
On 14 October 2022, the UK government announced that Corporation Tax will increase to 25% (currently 19%) from April 2023 as already legislated for, raising around £18 billion a year and acting as a down payment on its full Medium-Term Fiscal
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Mexico: Senate approves BEPS MLI
On 12 October 2022, the Mexican Senate approved the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Mexico signed the MLI on 7 June 2017. Mexico must now deposit its ratification
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Colombia: Congress approved Tax Reform Bill in the first debate
On 6 October 2022, the Colombian Congress approved Tax Reform Bill in the first debate. The Bill was presented to Congress on 8 August 2022. After the final approval of the Bill, the changes will become effective as of 1 January 2023. The main tax
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Belgium notifies TP penalties first time
The Belgian tax authorities have sent out the first penalty notifications for noncompliance to submit transfer pricing (TP) forms. Generally, TP documentation requirements is mandatory for Belgian entities exceeding the respective thresholds and
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Germany: CJEU has issued a decision on sanctions for non-compliance with TP documentation requirements
On 13 October 2022, the Court of Justice of the European Union (CJEU) ruled in case: C-431/21 on sanctions for non-compliance with transfer pricing (TP) documentation requirements. Under German law, there is a rebuttable presumption that the
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Mongolia signs MLI to implement tax treaty related BEPS measures
On 6 October 2022, Mongolia signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, at a signing ceremony held in Paris at the 14th meeting of the Inclusive Framework on BEPS. Mongolia
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Germany: Government publishes a draft bill for public CbC reporting
On 30 September 2022, the German Federal Ministry of Justice published draft legislation for the implementation of EU public country-by-country (CbC) reporting Directive 2021/2101 as regards the disclosure of income tax information by certain
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