Slovak Republic: OECD considers reforms to strengthen the recovery and future growth
On 13 January 2022 the latest OECD Economic Survey of the Slovak Republic was issued. The report notes that Slovakia’s recovery plan, supported by the EU, can give a boost to the economic recovery and growth, although there are downside
See MoreCroatia: Finance Ministry decides new interest rate between related parties
The Ministry of Finance announced a new interest rate of 2.68% on loans between related parties for 2022 before the beginning of the tax period in which it is applied. This means that interest is calculated at the rate of 2.68% of the minimum
See MoreSpain: BEPS MLI enters into force
On 14 December 2021, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, MLI entered into
See MoreSpain adopts the budget bill for 2022
On 29 December 2021, Spanish budget bill for fiscal year 2022 was published in the Spanish Official Gazette following its approval by the Spanish Congress and Senate. The bill introduces a minimum corporate tax rate of 15% of the tax base for
See MoreFrance: Government Officially publishes Finance Act 2022
On 31 December 2021, Government Officially published Finance Law for the year 2022. 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,
See MoreBulgaria announces fines for administrative violations will be 20% lower
On 29 December 2021, the National Revenue Agency (NRA) announced that taxpayers fined for administrative violations of tax laws can only pay 80% of the fine imposed. This is only allowed if the taxpayer pays the fine within 14 days of the
See MorePoland publishes safe harbor rate of interest, related-party loans in 2022
On 24 December 2021, the Polish Official Gazette published a Regulation No. 1192, establishing base interest rates and margin rates for the purposes of transfer pricing for individual and corporate income taxes. The “Safe Harbor” interest rate
See MoreCzech Republic: Finance Ministry issues Bulletin regarding MCAA-CRS
On 28 December 2021, the Finance Ministry published a Bulletin regarding the lists of jurisdictions exchanging Country-by-Country (CbC) reporting for the year 2021 on International Cooperation in Tax Administration and on Amendments to Other
See MoreCyprus amends corporate tax residency test
On 21 December 2021, an amendment to the Income Tax Law was published in the Cyprus Government Gazette. In accordance with the amended law, an additional corporate tax residency test is introduced. Under the new law, a company incorporated or
See MoreItaly: IRA Publishes guidance on CFC legislation
On 27 December 2021, the Italian Revenue Agency (IRA) has issued the publication of Circular No. 18/E, that provides guidance regarding the regulations for controlled foreign companies (CFCs) as amended by Article 4 of Legislative Decree No.
See MoreMalta seeks comments on draft Transfer Pricing Rules
On 22 December 2021, Malta’s Commissioner for Revenue (CFR) has published draft Transfer Pricing Rules on its website for public consultation. The consultation period will end on 28 February 2022, and the draft Transfer Pricing Rules shall come
See MoreFinland issues guidance on application of OECD guidelines for domestic TP rules
On 17 December 2021, the Finnish Tax Administration issued Guidance No. VH/5755/00.01.00/2021, on the application of OECD transfer pricing guidelines to domestic transfer pricing rules, effective from 31 December 2021. On 11 February 2020, the
See MoreIreland: Revenue issues an eBrief to update a manual on R&D tax credit
On 14 December 2021, the Revenue published an eBrief 226/21, which updates a manual to clarify certain aspects of the Research and Development (R&D) Tax Credit. The following aspects have been updated: to reiterate that measures to enhance
See MoreIreland: Government seeks Public Consultation on CbC tax reporting
On 20 December 2021, the Department of Enterprise, Trade and Employment is seeking the views of stakeholders through a Consultation on the transposition of the new EU directive requiring public country-by-country (CbC) reporting of income tax
See MoreCyprus: Tax department extends the deadline for submitting local CbCR reporting
On 20 December 2021, the Cyprus Tax Department published an announcement informing that the deadline for submission for local CbCR reporting due to the secondary filing mechanism (including Equivalent reporting) for the year 2020 is the 31st of
See MoreItaly announces statutory interest rate for 2022
On 15 December 2021, Italy has published the Ministerial Decree that increases the statutory interest rate to 1.25% with effect from 1 January 2022. Previously, the statutory interest rate was
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 MoreFrance: Tax Authority publishes a guide regarding the application of anti-hybrid rules
On 15 December 2021, the Tax Authority published a guide, which covers the measures implemented in compliance with the EU Anti-Tax Avoidance Directive as amended (ATAD1 and ATAD2) as part of the Finance Law for 2020. The hybrid mismatch measures
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