Spain: National Court issues rule on TP adjustment using median of arm’s length range
On 29 July 2023, the Spanish National Court issued a decision that provided clarification on the range of arm's length pricing adjustments applicable. In this case, Ferroli Spain, a Spanish manufacturer specializing in non-electric stoves,
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Ireland implements temporary solidarity contribution for fossil fuel sector
On 2 August 2023, the Minister for the Environment, Climate and Communications, Mr. Eamon Ryan, signed an order to commence the Energy (Windfall Gains in the Energy Sector) (Temporary Solidarity Contribution) Act 2023. The order is effective from 2
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Slovak Republic introduces draft law on OECD Pillar 2 global minimum tax
The Slovak Republic Ministry of Finance has initiated a public consultation process to get feedback on a draft law aimed at implementing a 15 percent global minimum corporate tax rate. The objective of this legislative proposal is to align
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Austria: Government plans to increase windfall tax on oil and gas companies
On 30 August 2023, the Austrian government announced a plan to tighten the windfall tax on oil and gas companies, in an effort to reduce their profits at a time of rising energy prices. The new tax will apply to profits that exceed a pre-crisis
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Ireland: Government releases second feedback statement implementing global minimum tax
On 27 July 2023, the Irish Government released second feedback statement on the transposition of the OECD Pillar Two global minimum tax rules in line with EU Council Directive 2022/2523 of 14 December 2022. The consultation period will run to close
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Germany released new draft guidance on anti-hybrid rules
On 14 July 2023, the German Ministry of Finance has released a draft decree outlining the application of the country's anti-hybrid rules, established in 2021 under the European Union (EU) Anti-Tax Avoidance Directive (ATAD) implementation Law. These
See MoreIreland: Revenue issues guidelines on EU tax dispute resolution mechanisms
On 17 July 2023, the Irish Revenue issued eBrief No. 165/23 on European Union (EU) tax dispute resolution mechanisms. Accordingly, Tax and Duty Manual Part 35-02-10 - Guidelines on the European Union (Tax Dispute Resolution Mechanisms) Regulations
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Hungary publishes decree amending extra-profit tax provisions for several industries
On 17 July 2023, Hungary published Government Decree 317/2023 in the Official Gazette amending Government Decree 197/2022 on temporary windfall taxes on additional profits. One of the most important changes is the extension of the windfall tax to
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Luxembourg: Parliament adopts bill on public CbC reporting
On 19 July 2023, the Luxembourg Parliament adopted Bill no. 8158 to implement public Country-by-Country (CbC) reporting in compliance with Directive (EU) 2021/2101. The bill conforms to the directive and sets the public reporting threshold at an
See MoreIreland: Revenue updates guidance on R&D tax credit
On 17 July 2023, the Irish Revenue issued eBrief No. 166/23 on research and development (R&D) corporation tax credit. Accordingly, Tax and Duty Manual Part 29-02-03 - Research and Development (R&D) Corporation Tax Credit - has
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Germany: MoF releases a revised draft bill on global minimum tax
On 10 July 2023, the German Ministry of Finance (MoF) released a revised draft bill, building on the initial discussion draft from 20 March 2023. significant changes include the introduction of a top-up tax compensation system within the minimum tax
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Luxembourg: Government submits draft bill on investment tax credit to Parliament
On 13 July 2023, the Luxembourg government submitted Bill 8276 to the Parliament on the modernization of the investment tax credit. The draft bill proposes several amendments to the investment tax credit framework. Notably, the overall investment
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Romania provides guidelines on public CbC reporting obligations
On 21 June 2023, the Romanian Government issued guidance to implement of the EU Public Country-by-Country (CbC) reporting Directive in the Official Gazette. On 1 September 2022, Romania became one of the first European Union (EU) Member States to
See MoreGermany: MoF releases draft bill on corporate tax reform
On 14 July 2023, the German Ministry of Finance (MoF) has released a draft bill known as the "Growth Opportunities Act." If passed, this act would mark Germany's most significant corporate tax reform since 2008. Key elements of the draft bill
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Czech Republic plans to increase tax rates
On 14 July 2023, the Ministry of Finance of the Czech Republic released a statement indicating that the Chamber of Deputies, the lower house of parliament, has given its initial approval to the government's recovery package. The package, which
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Lithuania updates definition of reverse hybrid entities to comply with ATAD2
Lithuania has amended its definition of a "reverse hybrid entity" to comply with the EU Anti-Tax Avoidance Directive (ATAD2). Previously, a Lithuanian entity was considered a reverse hybrid if it was owned by a tax resident of a foreign country, and
See MoreIreland: Revenue issues guidance for platform operators under DAC7
On 5 July 2023, the Irish Revenue issued eBrief No. 155/23, which provides guidance for platform operators for the exchange of information on income generated through digital platforms (DAC7). Council Directive 2011/16/EU (DAC) provides for the
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Lithuania: Seimas moves one step closer to tax reform
On 27 June 2023, the Lithuanian parliament (Seimas) gave its preliminary confirmation, to a tax reform package proposed by the finance minister. The reform measures include: Proposed changes to the tax framework encompass various aspects of
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