US: Treasury Department releases tax proposals from Budget 2023
On 28 March 2022, the Treasury Department of United States published details of tax proposals in the administration’s budget recommendations for FY 2023 in the “GreenBook.” The Greenbook describes following tax measures related to corporate
See MoreThailand extends transfer pricing disclosure deadline
On 25 March 2022, in response to the COVID-19 pandemic, the Thai Minister of Finance has announced an extension the deadline for filing the transfer pricing disclosure form to 30 May 2022 for the fiscal years starting on or after 1 January 2020 to
See MoreRussia raises the threshold for controlled transactions
On 22 March 2022, the Russian Parliament amended the criteria for controlled transactions for transfer pricing purposes. Accordingly, the general transaction threshold for transactions to be considered controlled transactions will be raised from
See MorePoland: MOF extends the deadline for APA implementation report
On 23 March 2022, the Polish Ministry of Finance has published a press release extending the deadline for APA implementation report to 30 June 2022. The deadline extension applies to companies with financial years ending between 1 December 2021 and
See MoreArmenia approves BEPS MLI
On 24 March 2022, the Armenian Cabinet approved the ratification of BEPS MLI. Armenia signed the convention on 7 June 2017. After completing the ratification process Armenia must deposit its ratification instrument to bring the MLI into force for
See MoreTurkey: Government submits a draft bill to the Parliament
On 25 March 2022, the Turkish Government submitted a draft bill to the Parliament. The bill contains various tax related measures including corporate tax rates, tax exemptions, and incentives. The main measure of the bill are as
See MoreHong Kong: IRD extends the CbC notification deadline
On 18 March 2022, the Hong Kong Inland Revenue Department issued a press release announcing an extension of the CbC notification deadline for accounting periods ending between 31 December 2021 and 28 February 2022. Under section 58H of the
See MoreAngola revises number of large taxpayers required to prepare TP documentation
On 15 March 2022, the Ministry of Finance of Angola has issued Order No. 1083/22 through which the list of the large taxpayers has been revised subject to the preparation of transfer pricing (TP) documentation. The listed large taxpayers must
See MoreSouth Africa: Cabinet approves BEPS MLI
The South African Cabinet approved on 23 March 2022, the submission to Parliament for the ratification of the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI). After the
See MoreRussia: 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
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