Ireland: Revenue publishes an eBrief to update DAC6 reporting guidance
On 1 March 2021, the Irish Revenue published an eBrief No. 014/21 regarding EU mandatory disclosure of reportable cross-border arrangements. On the similar day, the Revenue also published a Tax and Duty Manual, providing guidance to update the DAC6
See MoreDenmark: Government submits a draft Bill to amends various Acts
On 25 February 2021, the Government submitted a draft Bill, L 178, in the Parliament, which is a proposal for an Act amending the Depreciation Act, the Tax Assessment Act, the Pension Returns Taxation Act and the Sulfur Tax Act. The draft bill
See MoreIreland: Revenue issues an eBrief to announce updated TP guidance
On 24 February 2021, the Irish Revenue issued eBrief No. 37/21 regarding updated guidance on transfer pricing. On the similar day, the Revenue also published a Tax and Duty Manual-Part 35A-01-01, providing updated guidance on the operation of the
See MoreMalta: CFR extends electronic filing deadline of CIT returns
On 22 February 2021, Malta’s Commissioner for Revenue (CFR) has notified that the deadlines for the electronic filing of corporate income tax (CIT) have been extended as follows: Financial Year EndingManual Return DeadlineElectronic
See MoreHungary ratifies BEPS MLI
On 22 February 2021, the Hungarian Parliament approved the bill for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI will generally enter into
See MoreAustria: Parliament discusses about the delay on tax payments
Recently, the Austrian Parliament currently made a discussion regarding 2nd COVID-19-StMG. According to this, the deadline for the expiry of the general tax payments deferrals is to be postponed from 31 March 2021 until 30 June 2021. After the law
See MoreLuxembourg: Tax Authorities modifies guidance on DAC6
On 17 February 2021, the Luxembourg Tax Authorities has modified 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 following headings
See MoreCroatia deposits BEPS MLI ratification instrument
On 18 February 2021, the OECD announced that Croatia has deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI enters into force for
See MoreFrance: Court makes decision to reflect intra-group financial transactions
The French tax administration (FTA) published some decisions issued by the French courts and an administrative guidance regarding the arm’s length nature of intragroup financial transactions. Court’s decisions: In the last quarter of
See MoreCroatia: Government fixes related party interest rate for 2021
The Croatian Government has changed the arm’s length interest rate from 3.42% per annum to 3% per annum regarding loans between related parties for the year 2021. This rate is effective from 1st January 2021 and applies for loans between resident
See MoreGermany: Parliament further extends the deadline for 2019 tax returns
On 12 February 2021, the Germany’s upper house of Parliament further approved an extension in the deadline for 2019 tax returns. Accordingly, the deadline for the 2019 calendar year for tax returns submitted by tax advisors is extended up to 31
See MoreGreece: Tax Authority describes interest deduction limitation rules
On 11 January 2021, the Greek Public Revenue Authority (AADE) published Circular Ε. 2004 of 11 January 2021, which describes the application of the rule of limitation of interest as amended from 1 January 2019. According to the Circular, the
See MoreIreland: Revenue issues eBrief regarding guidance on CFC rules
On 12 February 2021, the Irish Revenue issued eBrief No. 027/21, which provides updated guidance regarding controlled foreign company (CFC) rules. On the similar day, the Revenue also published a Tax and Duty Manual, providing guidance of how to
See MoreDenmark: Government introduces new anti-avoidance rule
On 27 January 2021, the Government submitted a draft bill L 150, which proposes to introduce two defensive measures against the countries on the EU list of non-cooperating tax jurisdictions. According to the proposal, the Law will enter into force
See MoreFrance: Government publishes a country list with no CbC reporting obligation
On 3 February 2021, Government published a Decree of 3 February 2021, amending the order of July 6, 2017 amended in accordance with II of article 223 quinquies C of the general tax code. The decree comes into force the day after its publication.
See MoreLuxembourg: Parliament adopts Law on tax return deadline extension for 2019 and 2020
On 9 February 2021, the Luxembourg Parliament has adopted a draft law which was announced in December 2021 regarding the tax return filing deadline extension for 2019 and 2020 due to the COVID-19 pandemic. The deadlines are set for individual
See MoreBelgium plans to launch further TP audit cycle
On 11 January 2021, a number of selected Belgian taxpayers received a transfer pricing (TP) questionnaires from the tax authority’s special TP audit department. Based on noncompliant TP forms again audit cycles will be launched by the special TP
See MoreHungary: MOF publishes guidance on Mandatory Disclosure Rules
On 28 January 2021, the Hungarian Ministry of Finance published guidance on DAC6 reporting, which expands upon earlier guidance first issued in July 2020. The guidance serves as a general explanation on the provisions of the Hungarian MDR
See More