Italy: Final guidance on hybrid mismatches rules
On 26 January 2022, the Italian Revenue Agency (IRA) has declared the finalization of Circular No. 2/2022. The circular clarifies the hybrid mismatch rules that has introduced as part of the Decree No. 142 of 2018, which transposed the measures
See MoreRomania extends deadlines for tax return 2021
On 28 January 2022, the National Agency for Fiscal Administration (ANAF) of Romania has published a Notification No. 137 declaring the annual corporate income tax return and payment deadline is extended to 25 June 2022 for the tax year 2021.
See MoreLithuania publishes form for reportable cross-border arrangements
On 17 January 2022, the State Tax Inspectorate issued Order No. VA-7 of 14 January 2022, amending the rules for annual reporting on the use of reportable cross-border arrangements for DAC6. The order introduces the PRC914 notification form and
See MoreMalaysia: IRBM releases rules amending the restriction on deductibility of interest
On 31 January 2022, Inland Revenue Board of Malaysia (IRBM) published the Income Tax (Restriction on Deductibility of Interest) (Amendment) Rules 2022, amending the original rules published in 2019. The rules amend the definition of
See MoreOECD: 2022 Global Forum Capacity Building Report
On 3 February 2022 the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes published the 2022 Global Forum Capacity Building Report. Over the past decade the Global Forum has been involved in capacity building to
See MoreJordan: ISTD issues guide on CbC reporting requirements
On 2 February 2022, the Jordan Income and Sales Tax Department (ISTD) has issued a press release clarifying the issuance of a guide related to the preparation and submission of Country-by-Country (CbC) reports. ISTD has published the guidelines
See MoreJamaica joins CRS Multilateral Competent Authority Agreement
On 31 January 2022, the Organization for Economic Co-operation and Development (OECD) published an update regarding signatories of the multilateral competent authority agreement (MCAA) on automatic exchange of financial account information and
See MoreTransfer Pricing Brief: February 2022
ColombiaDocumentation/CbC reporting/Master file/Local file: On 20 December 2021, the Colombian Ministry of Finance and Public Credit has issued Decree 1778 specifying the deadlines for transfer pricing (TP) documentation, including local/master
See MoreMalta: CFR extends electronic filing deadline of CIT returns for 2022
On 27 January 2022, Malta’s Commissioner for Revenue (CFR) has notified that the deadlines for the electronic filing of corporate income tax (CIT) have been extended as follows: Financial Year EndingManual Return DeadlineElectronic
See MoreSingapore publishes TP Guidelines on indicative margin for related-party loans
On 4 January 2022, the Singaporean Inland Revenue Authority updated transfer pricing guidelines to set the 2022 indicative margin at 1.8% for related-party loans. The indicative margins are applied on each related party loan not exceeding
See MoreDominican Republic: DGII publishes thresholds for TP documentation and some tax issues
The Directorate General of Internal Revenue (DGII) has published Resolution No. DDG- AR1-2021-00001, which provides the general multiplier for inflation adjustments for the fiscal year ending 31 December 2021, including new transfer pricing
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UAE introduces 9% corporate tax rate
On 31 January 2022, the United Arab Emirates (UAE) Ministry of Finance (MoF) announced the introduction of a Corporate tax (CT) in the UAE that will be effective for financial years starting on or after 1 June 2023. The new regime, which is
See MoreSwitzerland publishes safe haven interest rates for 2022
The Swiss Federal Tax Administration (SFTA) has published two Circulars with safe-harbor interest rates 2022 for advances and intercompany loans in Swiss francs as well as in foreign currencies. Circular 195 of 27 January 2022 The minimum
See MoreCyprus: Tax department issues a new FAQs section on transfer pricing
On 24 January 2022, the Cyprus Tax Department published a new “Frequently Asked Questions (FAQs)” section on its website on Transfer Pricing (TP). The FAQs relate to the Interpretative Circular 3 issued on 30 June 2017 (Back-to-Back Circular).
See MoreOECD: Second Stage Peer Review of Guernsey under BEPS Action 14
On 24 January 2022 the OECD issued the stage 2 peer review report assessing Guernsey’s compliance with the minimum standard under Action 14 of the project on base erosion and profit shifting (BEPS). Action 14 is concerned with making tax dispute
See MoreOECD: Stage Two Peer Review Report on Jersey under BEPS Action 14
On 24 January 2022 the OECD’s Inclusive Framework published the stage 2 peer review report on Jersey’s compliance with the minimum standard under Action 14 of the project on base erosion and profit shifting (BEPS). Action 14 is concerned with
See MoreCzech Republic: Finance Ministry updates list of jurisdictions exchanging CbC reports
On 20 January 2022, the Finance Ministry published Finance Bulletin No.3/2022, which updates the list of jurisdictions participating in the exchange of country-by-country (CbC) reports for the 2021 reporting
See MoreIndia: CBDT further extends due dates of certain tax returns
On 11 January 2022, the Central Board of Direct Taxes (CBDT) has extended the filing of income tax returns and various audit reports for the 2021-22 tax years due to some difficulties reported by taxpayers and stakeholders due to the COVID-19
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