UK: Consultation on Technical Guidance on Uncertain Tax Treatment
On 18 January 2022 the UK launched a consultation on the technical guidance in relation to the legislation on uncertain tax treatment. Comments are invited by 1 February 2022, and the government intends to publish the final version of the guidance
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South Korea enacts tax revision bill for 2022
In December 2021, South Korea has enacted a tax revision bill for 2022 which was passed by Korea’s National Assembly on 2 December 2021. The tax revision bill is generally effective from fiscal years beginning on or after 1 January 2022. The
See MoreLithuania adopts important tax law changes
On 7 December 2021, the Lithuanian Parliament adopted several important amendments to the Law (No.IX-675) on the Corporate Income Tax of the Republic of Lithuania. The law proposed the following measures:Â Effective from 1 July 2022, the
See MoreAustralia: ATO declares review of APA program
On 12 January 2022, the Australian Taxation Office (ATO) has announced that it is undertaking a review of its advance pricing arrangement (APA) program. The APA program provides a valuable service delivering certainty on dealings with
See MoreNigeria: FIRS withdraws suspension of CbC reporting obligations for non-parent entities
On 4 January 2022, the Federal Inland Revenue Service (FIRS) issued a new Public Notice to announce that the withdrawal of its Public Notice of 6 May 2021 which suspended local filing obligations contained in Regulation 4 of the Income Tax (CbC
See MoreCroatia: Finance Ministry decides new interest rate between related parties
The Ministry of Finance announced a new interest rate of 2.68% on loans between related parties for 2022 before the beginning of the tax period in which it is applied. This means that interest is calculated at the rate of 2.68% of the minimum
See MoreJordan: Â ISTD publishes transfer pricing documentation forms
On 2 January 2022, the Jordan Income and Sales Tax Department (ISTD) has published new transfer pricing documentation forms (Arabic) in line with Regulation No. 40 of 7 June 2021. ISTD has published forms for Local File, Master File,
See MoreParaguay publishes new income tax return form with TP section
On 30 December 2021, Paraguay’s tax authorities published a new version of income tax return form including a new section to disclose transfer pricing (TP) adjustments. The new section of income tax return form differentiates the TP
See MoreSingapore updates Order on CbC Exchange of Multilateral Agreement
On 21 December 2021, Singapore published the Income Tax (International Tax Compliance Agreements) (Multilateral Competent Authority Agreement on The Exchange of Country-by-Country Reports) Order 2018. The change includes the addition of a
See MoreSpain: BEPS MLI enters into force
On 14 December 2021, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, MLI entered into
See MorePeru: SUNAT issues Decree on interest deduction limitation rules
On 30 December 2021, the Peruvian Tax Administration (SUNAT) has issued Supreme Decree 402-2021-EF in the Official Gazette clarifying the regulations for interest deduction limitation rules. From 1 January 2021, interest exceeding 30% of EBITDA
See MoreCosta Rica: Tax authority publishes new tax brackets for the year 2022
On 22 December 2021, the Costa Rican government and the Ministry of Finance posted a Decree No. 43375-H updating the corporate income tax thresholds for tax year 2022. The following corporate income tax rates will apply to the income of
See MoreTransfer Pricing Brief: January 2022
AustraliaSpecial rules for hybrid instruments or entities: On 16 December 2021, the Australian Taxation Office (ATO) issued Practical Compliance Guideline 2021/5 on imported hybrid mismatch rule relating to a practical administrative approach to
See MoreUkraine: Government approves amendments to the law ratifying the BEPS MLI
On 29 December 2021, the Ukraine Ministry of Finance has announced that the Government has approved amendments to the law ratifying the tax treaty related measures to prevent Base Erosion and Profit Shifting (MLI). BEPS MLI entered into force with
See MoreSaudi Arabia: ZATCA releases the third edition of transfer pricing guidelines
In November 2021, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) released the third edition of Transfer Pricing Guidelines in English. The first edition and second edition were released in March 2019 and May 2020 respectively. These
See MoreIreland: President signs Finance Bill 2021 into Law
On 21 December 2021, President signed the 2021 Finance Bill into Finance Act 2021, which provides for the implementation of the 2022 Budget measures as well as some necessary anti-avoidance measures and technical changes to the tax code. Some of
See MorePoland publishes safe harbor rate of interest, related-party loans in 2022
On 24 December 2021, the Polish Official Gazette published a Regulation No. 1192, establishing base interest rates and margin rates for the purposes of transfer pricing for individual and corporate income taxes. The “Safe Harbor” interest rate
See MoreCzech Republic: Finance Ministry issues Bulletin regarding MCAA-CRS
On 28 December 2021, the Finance Ministry published a Bulletin regarding the lists of jurisdictions exchanging Country-by-Country (CbC) reporting for the year 2021 on International Cooperation in Tax Administration and on Amendments to Other
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