Cyprus extends the imposition of administrative fines for DAC6 reporting
On 22 November 2021, the Cyprus Tax Department has published an announcement extending administrative fines for overdue submission of DAC6 reporting. The Tax Department informs that there will be no imposition of administrative fines for overdue
See MoreUS and India reach agreement on ‘equalization levy’ digital services tax
On 24 November 2021, the United States and India concluded an agreement on a transitional approach to the treatment of the current Indian E-commerce Equalization Levy (EL) in the transition period prior to the full implementation of Pillar 1
See MoreUS and Turkey sign digital service tax agreement
On 22 November 2021, the U.S. treasury department announced that the United States and Turkey have reached a political agreement with Turkey on the treatment of taxes on digital services (DST) in the transition period prior to the full
See MoreAzerbaijan modifies the Tax Code for TP, CbC Reporting, and CFC rules
On 16 November 2021, Azerbaijan has modified its Tax Code including three main changes regarding Transfer Pricing (TP), country by country (CbC) reports, and controlled foreign company (CFC) rules. The changes will be implemented from 1 January
See MoreKenya: KRA invites public comments on draft CbC reporting regulation
On 19 November 2021, Kenya Revenue Authority has opened a consultation on a country-by-country (CbC) reporting regulation. Accordingly, the National Treasury and Planning and Kenya Revenue Authority would like to inform Multinational Enterprises
See MoreMalta: CFR updates guideline on DAC6 reporting
On 17 November 2021, the Commissioner for Revenue (CFR) notifies that version 1.1 of the updated Guidelines on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements (DAC 6) are available for download here. Updates
See MoreSouth Africa: Parliament tables 2021 Tax Bills
On 11 November 2021, Tax Bills 2021 (Taxation Laws Amendment Bill (TLAB), Tax Administration Laws Amendment Bill (TALAB), Rates and Monetary Amounts and Amendment of Revenue Laws Bill (Rates Bill)) were tabled in the Parliament. The National
See MoreAustralia extends CbC reporting deadline
On 18 November 2021, the Australian Taxation Office (ATO) announced that country-by-country (CbC) reporting entities that have a CbC reporting obligation due by 31 December 2021 will now have until 4 February 2022 to file (lodge) such CbC reporting
See MoreSpain: Budget-2022 sets new minimum corporate tax rate
On 4 November 2021, the Spanish lower chamber passed the budget for 2022 which provides for a minimum corporate tax rate of 15% of the tax base for certain taxpayers from 2022. It applies to companies with a net turnover of at least 20 million
See MoreGermany publishes court decisions concerning the intercompany loans
On 4 November 2021, The German Ministry of Finance (MoF) published Tax Court Decision No. IR 32/17of 9 June 2021, on the taxation of corporate income based on unsecured loans to foreign related companies. In that case, a domestic company granted
See MoreAustralia amends guideline on simplified transfer pricing record-keeping options
On 11 November 2021, the Australian Taxation Office (ATO) amended its practical compliance guideline on simplified transfer pricing record-keeping options to provide maximum and minimum interest rates for low-level inbound and outbound
See MoreMexico: Congress approves Economic Package for the fiscal year 2022
On 26 October 2021, Mexican Congress has approved the tax reform for 2020 which was presented for the fiscal year 2022 which was presented on 8 September 2021. The Economic Package clarifies income tax law, value-added tax (VAT) law, excise tax
See MoreFinland announces to amend interest deduction limitation rules
On 4 November 2021, the government of Finland has published a proposal to the interest deduction limitation rules. The proposed amendments are particularly relevant for companies that rely on the “balance sheet test” which provides for an
See MoreRomania revises number of large taxpayers required to prepare TP documentation
On 29 October 2021, the Romanian National Tax Agency (NTA) published Order No. 1721 that revises the list of large taxpayers those are subject to prepare transfer pricing (TP) documentation. There are currently 2,940 large taxpayers until 31
See MoreTaiwan notifies affiliates of MNEs on submission of Master File and CbC report
On 9 November 2021, Taiwan’s National Tax Bureau of the Southern Area has indicated that affiliates of multinational enterprises in Taiwan, which meet the threshold to submit Master File or Country-by-Country (CbC) Report, shall not only disclose
See MoreColombia issues Draft Resolution to set UVT for 2022
On 8 November 2021, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales-DIAN) has issued a Draft Resolution to set out the tax unit value (Unidad de Valor Tributario – UVT) applicable for the year 2022. The UVT is
See MoreFinland: Parliament adopts bill to amend cross-border hybrid mismatch rules
On 29 October 2021, the Parliament of Finland has adopted the Bill No.204/2021 to amend cross-border hybrid mismatch rules, implementing the EU anti-avoidance directives. The bill includes following measures to transpose the reverse hybrid mismatch
See MoreColombia: Government issues regulations identifying preferential tax regimes
On 28 October 2021, the Colombian Government has issued Decree 1357, through which it partially regulates article 260-7 of the Tax Code. The Decree identifies criteria to consider a jurisdiction as a Preferential Tax Regime. This decree was
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