Spain 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
See MoreVietnam signs MLI to implement tax treaty related BEPS measures
On 9 February 2022, Vietnam signed the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent BEPS (the MLI). The Base Erosion and Profit Shifting (“BEPS”) project developed by the Organization for Economic Development and
See MoreG20: Communiqué Issued by the Meeting of Finance Ministers
On 18 February 2022 the G20 Finance Ministers and Central Bank Governors issued a communiqué following their meeting which took place on 17 and 18 February 2022. Economic Recovery The communiqué notes that the speed of the global economic
See MoreSouth Africa: Public Consultation on draft interpretation note on pricing of Intra-Group Loans
On 11 February 2022, the South African Revenue Services (SARS) published a draft interpretation note, determining the taxable income of certain persons from international transactions: intra-group loans and provides taxpayers with guidance on the
See MoreFrance: Government updates list of exempted countries for CbC report local filing obligations
On 14 February 2022, Government published Decree of 14 February 2022, which amends the Order 6 July 2017 pursuant to II of Article 223 quinquies C of the General Tax Code. The new Decree updates the exemption from local filing provided in the
See MoreOECD: Tax Report for the G20 Finance Ministers
On 18 February 2022 the OECD presented its tax report for the G20 Finance Ministers and Central Bank Governors. The main parts of the report are summarised below. Two-Pillar International Tax Package In October 2021 the OECD Inclusive
See MoreThailand introduces new CbC reporting requirements
On 12 January 2022, the Thai Revenue Department has issued Notification No. 419 with following additional provisions to the CbC reporting requirements: For CbC reporting, the “reporting entity” must register for e-filing via one of two
See MoreOECD: Global Forum launches Asia Initiative
On 16 February 2022 the first meeting of the Asia Initiative was held by the Global Forum on Transparency and Information Exchange for Tax Purposes. Taking part in the meeting were senior officials from 18 Asian members of the Global Forum and
See MoreTurkey ratifies CAA regarding CbC exchange arrangement with US
On 14 February 2022, the Turkish Revenue Administration has issued Presidential Decision No. 5191 in the Official Gazette, through which Turkey ratifies the competent authority arrangement (CAA) on the exchange of country-by-country (CbC) with US.
See MoreDenmark amends the transfer pricing documentation rules
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 of the due date for filing the tax return,
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