Germany publishes court decisions concerning the intercompany loans
On 4 November 2021, The German Ministry of Finance (MoF) published Tax Court Decision No. IR 32/17of 9 June 2021, on the taxation of corporate income based on unsecured loans to foreign related companies. In that case, a domestic company granted
See MoreIreland: Finance Department releases amendments to Finance Bill 2021
On 12 November 2021, the Finance Minister, Paschal Donohoe T.D., appreciated the approval by Government to a number of Government amendments to be put down at Committee Stage of the Finance Bill 2021. The Minster has decided not to proceed with
See MoreFinland announces to amend interest deduction limitation rules
On 4 November 2021, the government of Finland has published a proposal to the interest deduction limitation rules. The proposed amendments are particularly relevant for companies that rely on the “balance sheet test” which provides for an
See MoreRomania revises number of large taxpayers required to prepare TP documentation
On 29 October 2021, the Romanian National Tax Agency (NTA) published Order No. 1721 that revises the list of large taxpayers those are subject to prepare transfer pricing (TP) documentation. There are currently 2,940 large taxpayers until 31
See MoreAustria: Ministry of Finance proposes the tax reform for 2022
On 8 November 2021, the Austrian Ministry of Finance has proposed a draft bill on the ecosocial tax reform 2022 and submitted it for consideration by the parliament and the Federal Council. Subsequently, the corporate tax rate will reduce from 25%
See MoreFinland: Parliament adopts bill to amend cross-border hybrid mismatch rules
On 29 October 2021, the Parliament of Finland has adopted the Bill No.204/2021 to amend cross-border hybrid mismatch rules, implementing the EU anti-avoidance directives. The bill includes following measures to transpose the reverse hybrid mismatch
See MoreNetherlands introduces conditional withholding tax
On 2 November 2021, the parliament of the Netherlands approved the conditional withholding tax (WHT) rate of 25% on dividends paid to low tax jurisdictions. The conditional withholding tax will apply from 1 January 2024 on dividend payments to
See MoreItaly: Council of Ministers Approves Budget for FY 2022
28 October 2021, Italian Council of Ministers has issued a release declaring its approval of the Budget for FY 2022. The key tax measures include plastic tax and sugar tax is postponed until 2023, the VAT rate on feminine hygiene products is
See MorePortugal: Parliament rejects 2022 Budget Bill
On 27 October 2021, the Portuguese parliament rejected the government's 2022 budget bill (Bill 116/XIV/3). The draft bill was submitted in parliament on 11 October 2021 and includes various tax-related measures, including revised personal income
See MoreCyprus: Tax department publishes decree implementing regulations for DAC6
On 29 October 2021, the tax department of Cyprus published the Decree KDP 438/2021 for the implementation of the EU directives on reportable cross-border arrangements (DAC6). The decree provides guidance on the participants in a reportable
See MoreBelgium publishes late payment interest rate for 2022
On 27 October 2021, the Federal Public Service (SPF) published a notice with updated interest rate for late payment. According to the notice, the interest rate is set at 4% for the 2022 calendar year, which is as same as the 2021 calendar
See MoreGermany publishes court ruling on the arm’s-length interest rate on intercompany loans
On 21 October 2021, the German Ministry of Finance released Tax Court Decision No. IR 4/17(dated 18 May 2021), regarding the calculation of an arm's-length interest rate on intercompany loans. Under the ruling, the interest rate should be based
See MorePortugal introduces corporate tax credit due to COVID 19
On 11 October 2021, the Portuguese government submitted the draft budget for 2022 to the parliament. The main corporate tax measures include: The 2022 draft budget changed the patent box regulation, which provides for an increase in the
See MoreIreland adopts OECD authorized approach for TP of branches
On 21 October 2021, Minister for Finance, Paschal Donohoe TD, published the draft Finance Bill 2021, which underpins the Government’s ongoing support for the economy, particularly in response to the impact of Covid-19. It will introduce the
See MoreCyprus: MoF announces strategy for attracting companies providing tax incentives
On 15 October 2021, the Cyprus Ministry of Finance has presented the strategy for attracting companies for activating and expanding their activities in Cyprus. The strategy includes following tax incentives: Extension of tax exemption for
See MoreNorway: Government presents the National Budget for 2022
On 12 October 2021, the Government of Norway has presented the National Budget for 2022 in the Parliament includes the following tax proposals. Introduction of tax incentives for investments in small start-up companies.Reduced Bracket Tax and a
See MoreNetherlands: Amendments to revise CIT rate proposes for 2022 tax plan
On 5 October 2021, the amendments to the “2020 Tax Plan” were presented to the lower house of Parliament of the Netherlands. Further amendments to the “2022 Tax Plan” were presented on 15 October 2021 to the lower house of Parliament. The
See MoreDenmark: 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
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