Australia: 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 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 MoreIreland: Finance Ministry delivers the Budget 2022
On 12 October 2021, the Finance Ministry presented Budget 2022, which covers the following tax measures: The new minimum effective corporation tax rate will be 15%. However, Ireland will continue to offer the 12.5% rate for businesses with
See MoreNetherlands presents Budget for 2022
On 21 September 2021, the Dutch Budget for 2022 was presented. This year, the 2022 tax plan package mainly contains minor changes aimed at improving the tax system. In particular, improvements will be made to existing taxes in the areas of housing,
See MoreIreland: Government publishes Tax Strategy Group Papers prior to Budget 2022
On 16 September 2021, the Finance Department and the Department of Employment Affairs and Social Protection published Tax Strategy Group papers prior to Budget 2022. Some of the changes in the Budget papers are given below: Corporate tax As
See MoreIreland: Revenue updates TP rules for some qualifying companies
On 6 September 2021, the Revenue updated its guidance to assist some qualifying companies in accordance with Section 110 regarding the application of transfer pricing (TP) rules and other issues. Under Section 110, a company be a qualifying one if
See MoreIreland: Finance Ministry declares for a feedback statement on ATAD anti-hybrid rule
On 2 July 2021, the Finance Minister, Paschal Donohoe TD, launched a Feedback Statement on the Anti-reverse hybrid rule. The anti-hybrid rules are largely contained in ATAD2, which extended the basic anti-hybrid provisions of the first ATAD and
See MoreSlovenia: MoF proposes several amendments to tax changes
On 16 April 2021, the Slovenian Ministry of Finance (MoF) has proposed several amendments to tax changes including the Bill on Amendments to the Value Added Tax (VAT) Act, the Bill on Amendments to the Corporate Income Tax Act, and the Bill on
See MoreCanada: Finance Minister presents Budget 2021
On 19 April 2021, the Finance Minister, Chrystia Freeland, presented Budget 2021, which includes important business tax measures, digital service taxes, limitation of interest deduction, hybrid mismatch arrangements, transfer price cases, mandatory
See MoreIreland: Revenue publishes an eBrief to update guidance on anti-hybrid rules
On 29 March 2021, the Irish Revenue published an eBrief No. 068/21 to announce a manual to update the guidance on anti-hybrid rules. On the similar day, the Revenue also published a Tax and Duty Manual, which provides guidance on the anti-hybrid
See MoreSweden: Parliament accepts Bill to implement EU ATAD reverse hybrid mismatches
On 16 March 2021, the Swedish Parliament (Riksdag) has accepted Bill No. 2020/21:111 to implement EU Anti-Tax Avoidance Directive (ATAD) reverse hybrid mismatches. In this bill, it is proposed that rules be introduced regarding the tax treatment
See MoreIreland: President signs the Finance Bill 2020 into Law
On 19 December 2020, the President signed the Finance Bill 2020 into Law, which underpins the Government’s support for the economy in the face of Covid-19 pandemic and the ongoing threat of a no-deal Brexit. The Finance Act 2020 provisions
See MoreAustralia: ATO clarifying the operation of hybrid mismatch rules
Australia's hybrid mismatch rules have been updated with a number of technical amendments in order to clarify and improve the rules' operation. In the 2019–20 Budget on 2 April 2019, the Australian government announced the measure Tax
See MoreGreece: Parliament published two Laws to introduce various changes in transfer pricing context
On 31 July 2020 and on 29 July 2020, the Greek Parliament Officially published two Laws, L. 4714/2020 and L. 4712/2020 respectively regarding various sections of transfer pricing. The two Laws cover the following changes: Tax dispute Resolution
See MoreFinland publishes guidance on hybrid mismatch rules
On 3 July 2020, the tax authorities have published guidance no. VH/2738/00.01.00/2020 concerning the legislation on cross-border hybrid mismatches, transposing the hybrid mismatch rules, the EU Anti-Tax Avoidance Directive (ATAD) 2016/1164 and
See MoreIreland: Irish Revenue introduces new hybrid mismatch guide
On 8 July 2020, the Revenue published eBrief No. 137/20 on a new Tax and Duty Manual Part 35C-00-01, which provides an overview of the anti-hybrid rules that were introduced into Part 35C TCA 1997 by Finance Act 2019. This manual covers following
See MoreAustralia: Integrity rule law companion ruling finalized
In April 2019, Australian Taxation Office (ATO) released a draft Law Companion Ruling on the Organization for Economic Cooperation and Development (OECD) hybrid mismatch rules related to integrity rule. The ATO have now released draft LCR
See MoreGreece: Finance Ministry published a Bill regarding anti-hybrid rules for public consultation
On 7 July 2020, the Ministry of Finance published a draft bill related to the transposition of anti-hybrid rules for public consultation. This Bill includes a new article, Article 50 to amend the Article 66B and covers to the extent in where a
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