Switzerland 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 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 MorePortugal publishes new transfer pricing Legislation
On 26 November 2021, the Portuguese Tax Administration (PTA) published Order No. 268/2021, which replaces Regulation No. 1446-C / 2001 of December 21, 2001. The new regulation revises the rules for implementing the arm's length principle under
See MoreIndia: CBDT notifies the arm’s-length pricing variation limit for 2021-22
On 29 October 2021, the Central Board of Direct Taxes (CBDT) has published Notification No. 124/2021, which provides for a tolerance limit of 1% for wholesalers and 3% in all other cases for the arm’s-length pricing determination in 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 MoreIndia extends the validity of transfer pricing safe harbor rules
On 24 September 2021, the CBDT issued a new Notification No. 117/2021, to extend the applicability of the transfer pricing safe harbor rules. The extension applies for the 2020-21 and 2021-22 assessment years. Taxpayers opting for safe harbor rules
See MoreMexico: Executive Branch submits 2022 economic proposal to Congress
On 8 September 2021, the Mexican Executive Branch has submitted Economic Package for the fiscal year 2022 including a proposal of Tax Reform. The proposed 2022 Tax Law clarifies income tax law, value-added tax (VAT) law, excise tax (duty)
See MoreRussia increases the Interest rate from July 2021
On 23 July 2021, the Russian Central Bank announced the decision to increase the key rate from 5.5% to 6.5% with effect from 26 July 2021. For tax purposes, the key rate is important in relation to the safe harbor rates for interest income and
See MoreSwitzerland declares safe harbor interest rates
The Federal Tax Administration of Switzerland has published two separate circulars regarding safe harbor interest rate limits applicable to shareholder and related party loans in 2021. The rates may vary depend on whether the financing is in Swiss
See MoreOECD and Brazil: Call for Input on Safe Harbours and Simplification Issues
On 30 July 2020 the OECD and Brazil jointly launched a survey looking for comments on the development of safe harbours and other simplification measures. OECD and Brazil The survey is part of a project begun in February 2018 to review the
See MoreIndia: Central Board of Direct Taxes (CBDT) publishes finance act 2020
On 27 March 2020, the Central Board of Direct Taxes (CBDT) published the Finance Act 2020 that includes measures announced as part of the Union Budget 2020-2021 and others. The measures of the Finance Act generally apply from 1 April 2020 (or
See MoreSerbia: Ministry of Finance publishes safe harbor interest rates for 2020
The Serbian ministry of finance has published the Rulebook on arm’s length interest rates that are applicable for 2020, which apply to interest rates on loans and credits between associated parties. The Rulebook was published in the Official
See MoreSouth Korea: National Assembly enacts tax reform bill for 2019
On 31 December 2019, South Korea’s National Assembly has enacted tax reform bill for 2019 with a number of new measures added to the existing proposals including changes in transfer pricing measures. The new and amended tax measures are
See MoreTaiwan: MOF announces safe harbor rules for CbC report
On 10 December 2019, the Ministry of Finance (MOF) issued tax ruling no. 10804651540 providing exemption from CbC reporting for Taiwan entities under a MNE Group headquartered outside Taiwan. The safe harbor exemption guidance was issued in late
See MoreRussia reduces the Interest rate from September 2019
On 6 September 2019, the Russian Central Bank announced the decision to reduce the key rate from 7.25% to 7.00% with effect from 9 September 2019. For tax purposes, the key rate is important in relation to the safe harbor rates for interest
See MoreRussia reduces the interest rate from July 2019
On 26 July 2019, the Russian Central Bank announced the decision to reduce the key rate from 7.50% to 7.25% with effect from 29 July 2019. For tax purposes, the key rate is important in relation to the safe harbor rates for interest income
See MoreSerbia: Ministry of Finance publishes safe harbor interest rates for 2019
The Serbian ministry of finance has published the Rulebook on arm’s length interest rates that are applicable for 2019, which apply to interest rates on loans and credits between associated parties. The Rulebook was published in the Official
See MoreThailand enacts Transfer pricing law
On 21 November 2018, Thailand's new transfer pricing law was enacted and published in the Official Gazette and will be effective from 1 January 2019, which was approved by the National Legislative Assembly in 27 September 2018. Tax assessment
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