UK: Transfer Pricing and Diverted Profits Tax Statistics
On 28 April 2022 HMRC published the latest set of statistics relating to transfer pricing and the diverted profits tax. The latest release contains data up to end of the 2020/21 tax year. HMRC is anxious to reduce the amount of the tax gap,
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OECD: Peer Review Reports on Making Tax Dispute Resolution More Effective
On 14 April 2022 the OECD published a further set of peer review reports under BEPS Action 14 which is concerned with making tax dispute resolution mechanisms more effective. These reports set out the results of assessments under stage two of the
See MoreOECD: Second Stage Peer Review of Guernsey under BEPS Action 14
On 24 January 2022 the OECD issued the stage 2 peer review report assessing Guernsey’s compliance with the minimum standard under Action 14 of the project on base erosion and profit shifting (BEPS). Action 14 is concerned with making tax dispute
See MoreIreland: Revenue updates guidelines for requesting MAP assistance
On 23 December 2021, the Revenue published an eBrief No. 236/21 on the updated Manual for requesting Mutual Agreement Procedure (“MAP”) assistance in Ireland. The Guide has been updated to incorporate Council Directive (EU) 2017/1852 of 10
See MoreSpain: Tax authority publishes a guide and Q&As on MAP
On 19 November 2021, the tax authorities have issued a guide and questions and answers (Q&As) on mutual agreement procedures (MAPs) to provide taxpayers with guidance on the main aspects of MAP. The Q&As clarified that the Spanish
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 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 MoreTurkey: Parliament members submit a new Tax Bill to the Parliament
On 1 October 2021, Turkish Parliament members have submitted a new Tax Bill to the Parliament which includes tax filing periods, tax exemptions, and incentives. The key corporate tax measures of the Bill are: In the reduced corporate tax
See MoreThailand extends tax refunds deadline in MAP cases
On 23 August 2021, the Ministry of Finance of Thailand has issued a notification that provides an extension of the deadline to request a corporate or individual income tax refund for certain eligible persons whose standard time to request a tax
See MoreGermany publishes Guidance on MAP and arbitration procedures
On 27 August 2021, the Federal Ministry of Finance published guidance on mutual agreement (MAP) and arbitration procedures. The guide explains how to initiate procedures, how to carry out procedures, how to execute agreements, etc. The guidance
See MoreCanada: CRA replaces and abolishes a Circular regarding MAP
On 1 June 2021, the Canada Revenue Agency (CRA) published Information Circular IC71-17R6, which replaces and cancels Information Circular 71-17R5 dated January 1, 2005. This Circular describes several changes related to MAP. MAP filing
See MoreTaiwan: MOF issues Decree on cross-border bilateral, multilateral APAs under MAP
On 24 June 2021, the Ministry of Finance issued a Decree which stipulates that when tax collection authorities negotiate cross-border bilateral or multilateral advance pricing arrangements (APAs) (hereinafter referred to as "BAPAs") with the
See MoreMorocco publishes guidance on mutual agreement procedure
The Ministry of Finance (MoF) of Morocco has published guidance on the mutual agreement procedure (MAP), which provides a dispute resolution procedure to resolve tax treaty related disputes. MAP is designed to relieve double taxation, typically
See MoreSpain publishes a decree amending Mutual Agreement Procedure (MAP)
On 8 June 2021, the Spanish government has published a Royal Decree 399/2021 which amends the Regulation on Mutual Agreement Procedures (MAP) as approved by Royal Decree 1794/2008. The decree implements three packages of initiatives to enhance
See MoreUAE publishes guidance on mutual agreement procedure
The Ministry of Finance (MoF) of the United Arab Emirates (UAE) has published guidance on the mutual agreement procedure (MAP), which provides a dispute resolution procedure to resolve tax treaty related disputes. MAP is designed to relieve
See MoreMalta enacts Budget Measures Implementation Act 2021
On 16 April 2021, Malta has published and enacted Act to implement Budget Measures for the Financial Year 2021and other administrative measures (Act No. XVIII of 2021). The budget measures were announced in October 2020 which came into force on
See MoreOECD: Peer review reports under BEPS Action 14
On 15 April 2021 the OECD released peer review assessments under Action 14 of the project on base erosion and profit shifting (BEPS) which aims to make dispute resolution mechanisms more effective. These stage two monitoring reports relate to
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