Ireland: 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 MoreNorway releases proposed amendment to the petroleum taxation system
On 31 August 2021, the government of Norway has issued a release proposing amendment to the petroleum taxation system. Under the amendment, the Government is proposing to revise the special petroleum tax system as of 2022, replacing the rules on
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 MoreDenmark presents Budget for 2022
On 30 August 2021, the Minister of Finance presented the government's budget proposal for 2022. With its proposal for the Finance Act 2022, most of the measures presented focus on easing the country's transition out of the crisis and include a
See MoreUS: IRS publishes joint statement with Germany on the exchange of CbC reports
The Internal Revenue Service (IRS) published a joint statement with the competent authority of the United States of America and the competent authority of the Germany on the implementation of the spontaneous exchange of Country-by-Country Reports
See MoreUS: IRS publishes joint statement with France on the exchange of CbC reports
The Internal Revenue Service (IRS) published a joint statement with the competent authority of the United states of America and the competent authority of the French republic on the implementation of the spontaneous exchange of country-by-country
See MoreEU: Proposed carbon border tax criticised by BRICS countries
On 27 August 2021 a virtual BRICS ministerial meeting on the environment stated its joint opposition to the EU’s proposed carbon border adjustment mechanism and referred to it as discriminatory. The BRICS countries – Brazil, Russia, India,
See MoreGerman: Federal Constitutional Court voids 6% interest rate on back taxes
On 18 August 2021, the Federal Constitutional Court has published a press release stating that interest of 6% pa on tax back payments and tax refunds from 2014 is unconstitutional. Earlier, the First Senate of the Federal Constitutional Court
See MoreRomania approves BEPS MLI
On 19 August 2021, Romania approved the ratification of the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI). Romania must deposit its ratification instrument to bring the MLI into
See MoreGermany updates the CbC Reporting requirements based on the Annual Tax Act 2020
The Federal Ministry of Finance recently published a notice on the current issue of the Federal Central Tax Office's newsletter, which updates the country-specific (CbC) reporting requirements due to the 2020 Annual Tax Act. As a result of the
See MoreEU: Commission Letter Comments on Common Corporate Tax
On 3 August 2021 a letter addressed to the European Parliament on behalf of the European Commission confirmed that the single corporate tax system for the EU, to be known as Business in Europe: Framework for Income Taxation (BEFIT), would take into
See MoreDenmark proposes to reduce the TPD obligation for purely Danish transactions
On 23 June 2021, the Ministry of Finance submitted a draft bill for consultation. The bill proposed an amendment to the Danish Tax Control Act in order to relax the documentation requirements for transfer pricing for purely Danish transactions. It
See MoreLuxembourg updates electronic exchange and frequently asked questions of CbC report
On 20 August 2021, Luxembourg has announced that the section "Electronic exchange - country by country (CbC) reporting" as well as the frequently asked questions relating to the CbC declaration have been updated. Please note that the frequently
See MoreLuxembourg: Tax Authorities issues circular on updated loss carry-forward rules
On 10 August 2021, the Luxembourg Tax Authorities has published Circular No. 31, which clarifies the application of the loss carry-forward under the municipal business tax. Losses incurred with effect from 1 January 2017 are available for
See MoreDenmark: Government publishes a Bill to amend Tax Control and Assessment Act
On 23 June 2021, the Ministry of Taxation proposed a draft Bill to amend the Tax Control Act and the Tax Assessment Act (Competence for approval of the information form, etc., adjustment of the disclosure deadline for legal entities, accounting in
See MorePoland: Government announces draft legislation on tax reforms
On 26 July 2021, the Government of Poland has announced a draft legislation concerning following tax reform related to corporate taxation. New definition of the place of effective business management aimed at limiting situations in which Polish
See MorePoland: Draft bill on DST presents in Parliament
On 7 July 2021, a draft bill on digital services tax (DST) was submitted to Poland's lower chamber of parliament (the Sejm). The bill includes a proposal of 7% tax on digital sector enterprises, regardless of their place of establishment, with a
See MoreLuxembourg issues circular on administrative fines and penalties
On 28 July 2021, the Luxembourg Tax Authorities has issued Circular No. 67 to set administrative fines and penalties in cases of tax fraud, criminal fraud, and the cooperation between the tax administration and the judicial authorities. The
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