UK: New Tax Regime for Asset Holding Companies
The UK budget announcements on 27 October 2021 proposed that legislation would be included in the Finance Bill 2021/22 to set up a new tax regime for qualifying asset holding companies (QAHCs). This change is part of a broader review of the UK
See MoreUK: Notification of Uncertain Tax Treatment for Large Businesses
The UK budget announcements on 27 October 2021 included a new requirement for large businesses to notify HMRC when they take a tax position in their returns that is uncertain. Legislation would be included in the Finance Bill defining a large
See MoreNigeria issues new procedural rules for tax appellate tribunal
Recently, the Minister of Finance, Budget and National Planning issued new Tax Appeal Tribunal (Procedure) Rules 2021. The Rules replace the 2010 Rules and are intended to guide the practice and procedure of Tax Appeal Tribunal (“TAT“)
See MoreUkraine: Cabinet of Ministers adopts new APA procedures
On 28 October 2021, the Cabinet of Ministers of Ukraine has adopted new procedures of preliminary coordination of advance pricing agreements (APAs) in controlled transactions, as a result of which agreements on preliminary coordination of pricing,
See MoreCyprus: Tax department publishes decree implementing regulations for DAC6
On 29 October 2021, the tax department of Cyprus published the Decree KDP 438/2021 for the implementation of the EU directives on reportable cross-border arrangements (DAC6). The decree provides guidance on the participants in a reportable
See MoreTransfer Pricing Brief: November 2021
AustriaDocumentation-Requirement: On 7 October 2021, the Austrian Ministry of Finance published the updated Austrian Transfer Pricing Guidelines (Austrian Guidelines) 2021. The guideline provided guidance for those companies which fall under the
See MoreSingapore: IRAS updates e-Tax Guide on DTA to address arbitration procedure
On 23 October 2021, the Inland Revenue Authority of Singapore (IRAS) issued an updated edition of its e-tax guide on “avoidance of double taxation agreements” to add guidance on arbitration provisions in Singapore’s double tax
See MoreTurkey issues Regulations on mutual agreement procedures (MAP)
On 26 October 2021, Turkey has published Law No. 7338 on Certain Amendments on Tax Procedural Law and Certain Laws in the Official Gazette which clarifies provisions with respect to the domestic application of the mutual agreement procedure
See MoreGermany publishes court ruling on the arm’s-length interest rate on intercompany loans
On 21 October 2021, the German Ministry of Finance released Tax Court Decision No. IR 4/17(dated 18 May 2021), regarding the calculation of an arm's-length interest rate on intercompany loans. Under the ruling, the interest rate should be based
See MoreIreland adopts OECD authorized approach for TP of branches
On 21 October 2021, Minister for Finance, Paschal Donohoe TD, published the draft Finance Bill 2021, which underpins the Government’s ongoing support for the economy, particularly in response to the impact of Covid-19. It will introduce the
See MoreThailand introduces CbC reporting
On 15 October 2021, the Thai Revenue Department released guidance concerning the transfer pricing requirements with regard to country-by-country (CbC) reporting for accounting periods beginning on or after 1 January 2021. The guidance is referred
See MoreUN: Tax Committee Discusses Transfer Pricing Issues
In its virtual meetings from 19 to 27 October 2021 the UN Tax Committee is considering aspects of transfer pricing. Among topics that could be pursued further are practical risk assessment tools, transfer pricing aspects of marketing or trading
See MoreRussia: MOF publishes Tax Policy guidelines for 2022-2024
On 27 September 2021, the Ministry of Finance has reportedly issued the tax policy guidelines for 2022-2024, which includes the following tax measures: The introduction of new corporate and individual tax rules for taxing digital asset
See MoreUN: Tax and the Sustainable Development Goals
On 19 October 2021 the discussions of the UN Tax Committee covered issues around the role of taxation in achieving the sustainable development goals (SDGs). The work of the UN Committee can help countries to achieve their commitments related to
See MoreNetherlands: Amendments to revise CIT rate proposes for 2022 tax plan
On 5 October 2021, the amendments to the “2020 Tax Plan” were presented to the lower house of Parliament of the Netherlands. Further amendments to the “2022 Tax Plan” were presented on 15 October 2021 to the lower house of Parliament. The
See MoreUN: Meetings of the Committee of Tax Experts
The UN Committee of Experts on International Cooperation in Tax Matters is holding its 23rd session as a series of virtual meetings between 19 and 28 October 2021. The issues to be covered include the following: Tax and the Sustainable
See MoreDominican Republic: Government establishes thresholds and filing obligation of CbC report
On 5 October 2021, the Government established specific regulations for the country-by-country report through general standard on August 2021. The general rule is aligned with the model legislation included in the OECD’s base erosion and profit
See MoreDenmark: Parliament considers bill to relax rules on TP documentation
On 6 October 2021, the Danish parliament is taking into account draft bill L 7, which proposed an amendment to the Danish Tax Control Act in order to relax the documentation requirements for transfer pricing for purely Danish transactions. The
See More