Ukraine: 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
See MoreMalta seeks comments on draft Transfer Pricing Rules
On 22 December 2021, Malta’s Commissioner for Revenue (CFR) has published draft Transfer Pricing Rules on its website for public consultation. The consultation period will end on 28 February 2022, and the draft Transfer Pricing Rules shall come
See MoreIceland sets 31 January 2022 deadline for 2021 CbC notification
On 22 December 2021, Iceland published the Notice No.1490/2021 which provides that the CbC report notification in respect of the 2021 fiscal year is to be submitted by 31 January 2022. Companies must designate a company group member to submit CbC
See MoreFinland issues guidance on application of OECD guidelines for domestic TP rules
On 17 December 2021, the Finnish Tax Administration issued Guidance No. VH/5755/00.01.00/2021, on the application of OECD transfer pricing guidelines to domestic transfer pricing rules, effective from 31 December 2021. On 11 February 2020, the
See MoreIreland: Government seeks Public Consultation on CbC tax reporting
On 20 December 2021, the Department of Enterprise, Trade and Employment is seeking the views of stakeholders through a Consultation on the transposition of the new EU directive requiring public country-by-country (CbC) reporting of income tax
See MoreOECD: Updates to Transfer Pricing Country Profiles
On 13 December 2021 the OECD released updated transfer pricing country profiles for 18 countries, together with new transfer pricing profiles for Albania, Kenya and the Maldives. The OECD has now created transfer pricing profiles for a total of 63
See MoreCyprus: Tax department extends the deadline for submitting local CbCR reporting
On 20 December 2021, the Cyprus Tax Department published an announcement informing that the deadline for submission for local CbCR reporting due to the secondary filing mechanism (including Equivalent reporting) for the year 2020 is the 31st of
See MoreThailand revises CbC reporting deadline
On 23 December 2021, the Thai Revenue Department has published a notification on amendments to the filing deadlines for Country-by-Country (CbC) reports. Previously CbC report filing deadline was as same as the annual tax return deadline,
See MoreIreland: Revenue updates guidelines for requesting MAP assistance
On 23 December 2021, the Revenue published an eBrief No. 236/21 on the updated Manual for requesting Mutual Agreement Procedure (“MAP”) assistance in Ireland. The Guide has been updated to incorporate Council Directive (EU) 2017/1852 of 10
See MoreOECD: Peer Review Report on Harmful Tax Practices
On 14 December 2021 the OECD published a report entitled: Harmful Tax Practices – 2020 Peer Review Reports on the Exchange of Information on Tax Rulings. The standard under Action 5 of the OECD/G20 action plan on base erosion and profit
See MoreFrance: Tax Authority publishes a guide regarding the application of anti-hybrid rules
On 15 December 2021, the Tax Authority published a guide, which covers the measures implemented in compliance with the EU Anti-Tax Avoidance Directive as amended (ATAD1 and ATAD2) as part of the Finance Law for 2020. The hybrid mismatch measures
See MoreSouth Africa: SARS opens a public consultation for an APA program
On 10 December 2021, the South African Revenue Service (SARS) made an announcement for inviting public comments for a model and draft legislation regarding Advance Pricing Agreement (APA) system until the end of January 2022. The draft model is
See MoreAustralia: ATO issued PCG 2021/5 on imported hybrid mismatch rule
On 16 December 2021, the Australian Taxation Office (ATO) issued Practical Compliance Guideline 2021/5 on imported hybrid mismatch rule – ATO’s compliance approach (PCG 2021/5) relating to a practical administrative approach to the imported
See MoreLuxembourg updates the list of jurisdictions for exchanging CbC reports
On 13 December 2021, the Luxembourg Ministry of Finance published Grand-Ducal Regulation of 9 December 2021 in the Official Gazette amending Grand-Ducal Regulation of 13 February 2018. The Regulation updates the list of
See More