Ireland: Revenue issues eBrief on anti-hybrid rules guidance
On 29 June 2022, the Irish Revenue published an eBrief No. 137/22 to announce a manual to update the guidance on anti-hybrid rules. Accordingly, Tax and Duty Manual Part 35C-00-01 - Guidance on the Anti-hybrid rules - has been updated for
See MoreGreece enacts ATAD’s reverse hybrid rule
On 30 June 2022, the government of Greece enacted legislation implementing ATAD's reverse hybrid rule with retroactive effect from 1 January 2022. The rule does not apply to collective investment vehicles. The new rule applies to situations where
See MoreSpain confirms the completion of its internal procedures for the entry into force of the MLI
On 28 June 2022 OECD published the update status of signatory countries regarding BEPS MLI. Accordingly, on 1 June 2022, Spain submitted its notification confirming the completion of its internal procedures for the entry into force of the
See MorePoland: MoF extends the filing deadline for corporate income tax return
On 22 June 2022, the Polish Ministry of Finance has published a draft decree extending the deadline for submitting the CIT-8E return. Accordingly, the deadline for submitting the CIT-8E return is 30 September 2022. The extension applies to all
See More
Hungary: Finance minister presents 2023 budget bill to parliament
On 22 June 2022, the Hungarian finance minister submitted the 2023 Budget Bill in parliament providing following tax measures related to transfer pricing changes. The bill proposes to revise the regulation of the application of the interquartile
See MorePoland increases late payment interest rates in fifth time
On 15 June 2022, the Polish Ministry of Finance fifth time published the increased interest rates on tax arrears as well as on the late payment. Accordingly, the standard rate is increased from 13.5% to 15% per annum; the reduced rate (applies when
See More
Austria: MOF Updates Guidance on COVID-19 treaty Issues
On 20 June 2022, the Ministry of Finance published a Circular (no. 2022-0.433.029 of 17 June 2022) clarifying various tax treaty issues that have arisen due to the COVID-19 pandemic, including permanent establishments(PE) and the application of the
See MoreLuxembourg: Tax Authority updates guidance on CFC rules
On 17 June 2022, the Luxembourg Tax Authority published Circular n°164ter/1 (the guidance) on the controlled foreign corporation (CFC) rules. The guidance includes the following topics: Foreign controlled companies with regard to corporate
See MorePoland extends the deadlines for submitting transfer pricing documentation
On 10 June 2022, the President of the Republic of Poland signed the Act of June 8, 2022 providing for the extension of the deadlines for submitting a declaration on the preparation of local transfer pricing documentation (TP statements) and TPR
See MorePortugal approves the Budget for 2022
On 27 May 2022, the Budget for 2022 has passed by the parliament. The budget includes the following tax-related measures: The Budget bill increases the exemption of qualifying taxable IP income under the patent box regime from 50% to 85%;
See More
Italy: New circular clarifies application of ALP
On 24 May 2022, the tax authority of Italy has issued Circular No. 16/E, that clarifies the application of the arm's length principle (ALP) in transfer pricing as per Decree of 14 May 2018 and Decree No. 50 of 24 April 2017 as converted by Law No.
See More
Netherlands publishes latest DAC6 reporting guidelines
The Netherlands Tax and Customs Administration have published latest user guidelines for the use of the Mandatory Disclosure/DAC6 data portal for reporting potentially aggressive cross-border tax arrangements. As a result of the Dutch
See MoreMalta: CFR notifies corporate income tax return for the assessment year 2022
On 31 May 2022, Malta’s Commissioner for Revenue (CFR) notified that the year of assessment 2022 electronic corporate income tax return is available on online services. Although such returns may be downloaded and filled in, the facility to upload
See More
WHO: World Health Organisation looks at the effect of the tobacco industry on the environment
On 29 May 2022 the World Health Organisation (WHO) published a document entitled Tobacco: Poisoning Our Planet looking at the environmental damage caused by the tobacco industry. The report looks at the damage done to the environment throughout
See MoreEstonia deposits new notifications under Article 35(7)(b) of the BEPS MLI
On 1 June 2022, the Organization for Economic Cooperation and Development (OECD) announced that the Republic of Estonia notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the
See MoreLuxembourg issues guidance on non-deductible interest and royalty expenses
On 31 May 2022, the Luxembourg Tax Authorities published Circular L.I.R. no. 168/2 which clarifies the non-deductibility of interest or royalties paid to associate enterprises established in countries that are “blacklisted” as being
See MoreRomania: BEPS MLI in Force
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Romania on 1 June 2022. With regard to the tax treaties between Romania and other countries for which
See MorePoland: MoF reply to parliamentary inquiry on transfer pricing information
On 30 May 2022, the Treasury Department responded to a Parliamentary inquiry (No. 31287) regarding the rules for reporting certain transfer pricing information to be reported on the TPR-C form. According to response, the TPR-C form can be
See More