Czech Republic: Supreme Court makes a decision of a TP case on related party transaction
Recently, the Supreme Administrative Court (SAC) held in judgment 7 Afs 398/2019 – 49 of a transfer pricing (TP) case that tax administrators may assess additional tax based on overall profitability not just for related-party transactions, but
See MoreLuxembourg: Tax Authorities updates guidance on DAC6
On 4 May 2022, the Luxembourg Tax Authorities has updated guidelines concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) as per Council Directive (EU) 2018/822 of 25 May 2018. The guidance mainly covers
See MoreBulgaria releases updated guidelines on CIT
On 11 May 2022, the National Revenue Agency released an updated version of the 2022 Corporate Tax Handbook. The publication contains an overview of the applicable rules in the Corporate Income Tax
See MoreBelgium declares CIT return filing Deadline for tax year 2022
On 9 May 2022, the Federal Public Service Finance (SPF) of Belgium has issued a Notice declaring that the corporate income tax (CIT) return submission deadline is 17 October 2022 for the fiscal years ending from 31 December 2021 to 28
See MorePortugal extends the corporate income tax return deadline
Recently, the Portuguese government has provided a brief extension to the corporate income tax return deadline for the 2021 fiscal year. Typically the deadline is 31 May 2022, for taxpayers with a fiscal year that follows the calendar year. The new
See MoreMalta: CFR publishes FAQs on DAC6
On 29 April 2022, Malta’s Commissioner for Revenue (CFR) has published “frequently asked questions” (FAQs) on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements (DAC6). The FAQs contains the definition of
See MorePoland: MoF publishes draft decree changing the TP reports
On 25 April 2022, the Polish Ministry of Finance published a draft decree to change the scope of data and information to be disclosed via transfer pricing reports. The changes introduced by the draft decree include limiting the scope of transfer
See MoreSpain publishes corporate income tax return form for FY 2021
On 28 April 2022, Spain published an Order HFP/379/2022 in the Official Gazette, approving the forms and instructions for the corporate tax and Non-Resident Income Tax returns for periods from January 1 to 31 December 2021. The regulation will come
See MoreGreece: AADE issues a Circular regarding MCAA for the year 2020
On 18 April 2022, the Greek Public Revenue Authority (AADE) published Circular A.1051 of 18 April 2022, which determines the lists of jurisdictions with which Greece wants implement the Multilateral Competent Authority Agreement on the exchange of
See MoreDenmark introduces new filing requirements for TP documentation
Recently, the Danish Ministry of Finance introduced an obligation to file a transfer pricing documentation (TPD) with the Danish Tax Authorities on an annual basis. For the financial years beginning on or after 1 January 2021, the new law requires
See MoreBulgaria: Parliament considers a Bill to ratify BEPS MLI
On 15 April 2022, Parliament is considering a bill to ratify the Multilateral Convention Implementing Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (MLI). After the internal ratification process is complete, Bulgaria must
See MoreItaly issues latest tax return models with instructions
On 22 April 2022, the tax authority of Italy issued latest models, instructions, and technical specifications for tax returns, that effective for tax filing in 2022 in respect of the 2021 tax period. The updates are
See MorePoland increases late payment interest rates in third time
On 12 April 2022, the Polish Ministry of Finance third time published the increased interest rates on tax arrears as well as on the late payment. Accordingly, the standard rate is increased from 10% to 12% per annum; the reduced rate (applies
See MoreEU: Public Consultation on Minimum Rates of Alcohol Excise Duty
On 11 April 2022 the European Commission began a consultation on the minimum rates of alcohol excise duty in the EU. The consultation will continue until 4 July 2022. The consultation aims to gather the views of the relevant stakeholders on
See MoreCroatia: Tax Administration declares CbC notification deadline
On 11 April 2022, the Tax Administration declared that the notification deadline for submitting Country-by-Country (CbC) report until 2 May 2022. This deadline applies for multinational entities
See MoreGreece: Government introduces new rules for interest deduction restriction
On 28 March 2022, Government published Law No. 4916/2022, which establishes new group escape rules for the 30% of EBITDA interest deduction restriction. The new group scape rule was made optional when the Greek interest restriction rules were
See MoreCyprus: Tax department publishes FAQs on DAC6 reporting
On 8 April 2022, the Tax Department of Cyprus has posted online Frequently Asked Questions (FAQs) regarding reportable cross-border tax arrangements (DAC6). The FAQs are currently available in Greek language and covered following
See MorePoland: MOF launches public consultations for TP method on resale price
On 4 April 2022, the Polish Ministry of Finance launched a public consultation on draft guidelines clarifying the resale pricing method for determining the arm's length value of transactions between associated parties. The guidance clarifies,
See More