Denmark: 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 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 MoreCyprus clarifies bilateral agreement with US on exchange of CbC report
On 7 October 2021, the Cyprus Tax Department informs all legal entities and their representatives that the bilateral Competent Authority Arrangement (CAA) for the exchange of Country-by-Country (CbC Reports) between Cyprus and the United States of
See MoreSpain deposits BEPS MLI ratification instrument
On 28 September 2021, Spain deposited its instrument of ratification for the BEPS MLI. On 7 June 2017, Spain signed this convention and the MLI will enter into force on 1 January 2022 for
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 MoreSweden proposes the Budget Bill for 2022
On 20 September 2021, the Ministry of Finance has proposed the Budget Bill for 2022. The budget includes the following tax measures: The introduction of a modernized withholding tax on dividends paid to non-residents, including a standard
See MoreFinland: Supreme court makes a decision on arm’s length range and TP adjustment
On 13 September 2021, the Finnish Supreme Administrative Court (SAC) published a decision addressing the use of comparable data and the range of results in calculating transfer pricing adjustments. The case concerned a company, Finnish A Oy,
See MorePoland: Lower chamber of parliament passes the tax reform bill
On 1 October 2021, the lower chamber of parliament (the Sejm) of Poland has passed the 3rd reading the bill for the so-called “Polish Deal” tax reform bill. The bill proposes to several tax reform measures including new minimum corporate tax,
See MorePoland: Government plans to extend the scope of CFC rules
On 8 September 2021, the Polish government submitted a bill to the Parliament including the proposal extending the application of the CFC rules. The proposal includes the following changes: Extension of the definition of a foreign legal entity
See MoreCyprus: MoF further extends the deadline for e-filing return
On 24 September 2021, Cyprus’s Ministry of Finance has issued a decree providing further extension of electronic submission of tax returns for business (TD4) and personal (TD1A) for the fiscal year 2019. The new deadline is 30 November 2021.
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 MoreFrance: Government presents 2022 Finance Bill to National Assembly
On 22 September 2021, the Minister of Economy, Finance and Recovery, Bruno Le Maire and the Minister Delegate in charge of Public Accounts, Olivier Dussopt, presented 2022 Finance Bill to the National Assembly. Some of the proposed changes of this
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 MoreItaly launches public consultation on draft circular on TP documentation requirements
The Italian tax authorities have introduced a public consultation on the draft circular clarifying transfer pricing (TP) documentation requirements. Comments should be submitted by 12th October 2021 to the email
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 MoreDenmark plans to make permanent the tax incentives for R&D
On 7 September 2021, the Danish government proposed to make permanent the current temporarily increased deduction for research and development expenses of companies under an economic and social plan. An increased deduction of 130% of R&D
See MoreGreece: Prime Minister declares reduced CIT rate for SMEs
On 11 September 2021, the honorable Prime Minister, Kyriakos Mitsotakis, made a speech in Thessaloniki International Fair regarding tax measures. According to his speech, corporate tax rate will be reduced from 24% to 22%. In addition, small and
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