Azerbaijan 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 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 MoreUK: 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 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 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 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 MoreAustria releases the new transfer pricing guideline for 2021
On 7 October 2021, the Austrian Ministry of Finance published the updated Austrian Transfer Pricing Guidelines (Austrian Guidelines) 2021. The Austrian Guidelines 2021 are an essential interpretative aid for the application of the arm’s-length
See MoreCyprus: Tax Department extends the DAC6 reporting deadlines
On 21 September 2021, the Tax Department of Cyprus has issued a notice extending the DAC6 reporting deadlines. Accordingly, there will be no imposition of administrative fines for overdue submission of DAC6 information that will be submitted until
See MoreUkraine: STS clarifies the controlled transactions criteria for TP purposes
Recently, the State Tax Service (STS) has clarified the criteria for classifying transactions between related parties (Ukrainian residents and non-residents) as controlled for transfer pricing (TP) purposes. Under Ukrainian transfer pricing
See MoreUkraine issues taxation of income of non-residents
On 27 Aug 2021, the Ukrainian Ministry of Finance has issued Order No. 480 regarding the taxation of income of non-residents, which are equated to dividends. The Order provides clarification on the application of the new rules of taxation of income
See MoreCyprus: Tax Department issues update XML Schema for DAC6/MDR submissions
On 29 July 2021, the Cypriot Tax Department published an announcement regarding a new XML Schema that entered into force on 5 August 2021. The XML should be used by Intermediaries and Taxpayers to submit the information for the purposes of the
See MoreFrance: Tax authority suspends DAC6 filing services
Recently, the Tax Authority has published a notice to announce that the online service for reporting on DAC6 cross-border arrangements will be suspended in the private and professional areas from July 29, 2021 until the beginning of September 2021.
See MoreIreland: Revenue issues an eBrief to announce the reopening of DAC6 reporting portal
On 20 July 2021, the Revenue published an eBrief 142/21 and a tax and duty manual, which amend filing guidelines for DAC6 at Section 7.4 to include a revised date for the re-opening of the portal of 17 August 2021. This portal will be temporarily
See MoreSri Lanka amends transfer pricing regulations
Sri Lanka has published amended Transfer Pricing (TP) Regulations that update the existing regulations of 2018. The amended regulations were published in the Official Gazette on 2 March 2021 and apply retroactively from 1 April 2020. The
See MoreKenya enacts Finance Act 2021
On 1 July 2021, Kenya published the Finance Act 2021 in the official gazette. The act was signed into law by the president on 29 June 2021. The act was presented to Parliament by the Kenyan Treasury Cabinet Secretary on 4 May 2021. The act
See MoreCyprus: Tax department issues a notice extending penalty relief for DAC6 reporting
On 3 June 2021, the Cyprus tax department has issued a notice providing an extension to the imposition of administrative fines for overdue submission of DAC6 reporting. The Tax Department informs that there will be no imposition of
See MoreJordan introduces transfer pricing rules for MNE groups
On 7 June 2021, the Hashemite Kingdom of Jordan has published Regulation No. 40 of 2021 in the Official Gazette. The Regulation has introduced transfer pricing rules for multinational entity (MNE) groups with effect from 7 July 2021. The Regulation
See MoreKenya publishes Finance Bill 2021
On 5 May 2021, the Parliament of Kenya has published the finance bill 2021 providing the following tax measures: Reintroduce the definition of the term ‘‘Control” The definition of the term “control” was deleted with the
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