Russia: FTS clarifies the application of transfer pricing control under sanctions
On 14 March 2022, the Federal Tax Service (FTS) published guidance (Letter No. ШЮ-4-13/2724) stipulating that the application of sanctions against Russian individuals and legal entities may adversely affect the economic conditions of the
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 MoreSweden Updates CbC reporting guideline
On 14 March 2022, the Swedish Tax Agency updated the country-by-country reporting (CbC) guidelines for multinational companies (MNEs). The guidelines introduced the following updates: 1) Annual notification requirements for Swedish
See MoreNigeria: FIRS posts digital FAQs regarding transfer pricing
On 15 March 2022, the Federal Inland Revenue Service (FIRS) made a post of frequently asked questions and answers (FAQs) related to transfer pricing (TP) through online. This includes applicable regulations and their scope; documentation
See MoreKazakhstan: Government invites public comments regarding transfer pricing amendments
On 16 March 2022, the State Revenue Committee announced that they opened a public consultation on a draft bill to amend transfer pricing rules. The deadline for this public comments is 8 April 2022. The draft Bill contained the following measures
See MoreBolivia: Deadline extension for compliance with tax obligations for private companies
Recently, the Tax administration issued a guidance (RND 1022-04), which extends the deadline for the presentation of Sworn Declarations and payment of tax obligations until 18 March 2022 for the fiscal period February 2022, of the Public Entities
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 MoreOECD: Tax Administration Capacity Building in Relation to the Mining Sector in Latin America
On 15 March 2022 the OECD published a blog post on its website commenting on the importance of capacity building to enable tax administrations to collect a fair amount of tax and royalties from mining activities. The post highlighted the
See MoreSweden: Administrative court rules in favor of the taxpayer in TP case
On 28 February 2022, the Swedish Administrative Court announced its ruling and have supported Pandox AB claim in the company’s dispute with the Swedish Tax Agency. Pandox is a chain company owning around 157 hotel properties in 15
See MoreSpain adopts ATAD2 anti-hybrid rules
On 9 March 2022, Spanish government amended the Corporate Income Tax (CIT) law and the Non-Resident Income Tax (NRIT) law to address hybrid mismatches. The purpose of these amendments is to enact into Spanish domestic law the anti-hybrid rules
See MoreJordan: ISTD publishes transfer pricing and CbC Notification forms
Recently, the Jordan Income and Sales Tax Department (ISTD) has published new transfer pricing and country-by-country (CbC) Notification forms (Arabic language) in line with executive instructions No. 3 of 16 September 2021. Transfer pricing
See MoreGreece: AADE issues a Circular to provide guidance on CFC rules
On 23 February 2022, the Greek Public Revenue Authority (AADE) published Circular E. 2018 of 23 February 2022, providing guidance on the application of Controlled Foreign Companies (CFC rules). This is introduced as from 1 January 2019 in line with
See MoreRomania deposits instruments for the ratification of the Multilateral BEPS Convention
On 28 February 2022, Romania has deposited its instrument of approval or ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Convention or MLI), which now covers over
See MoreTransfer Pricing Brief: March 2022
DenmarkDocumentation-Timing and deadlines: On 31 January 2022, the Danish Ministry of Finance issued updated guidance regarding amendments to the transfer pricing rules requiring the submission of the transfer pricing documentation within 60 days
See MoreOECD: Updates to Transfer Pricing Country Profiles
On 28 February 2022 the OECD released updated transfer pricing country profiles for 22 countries, together with new transfer pricing profiles for six more countries. This is the third batch of updates for 2021/22. The OECD transfer pricing
See MoreChile joins International Compliance Assurance Program
On 24 February 2022 the OECD announced that Chile has joined the International Compliance Assurance Program (ICAP). The ICAP is a voluntary risk assessment and assurance program whose objective is to facilitate greater cooperation in tax compliance
See MoreOECD announces that Chile has joined the ICAP
On 24 February 2022 the OECD announced that Chile has joined the International Compliance Assurance Program (ICAP). The ICAP is a voluntary risk assessment and assurance program whose objective is to facilitate greater cooperation in tax
See MoreOECD: Consultation on Tax Base Determinations under Pillar One
On 18 February 2022 the OECD launched a public consultation in relation to tax base determinations for Amount A of Pillar 1 of the two-pillar international tax initiative. This is a continuation of the work by the Inclusive Framework in relation to
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