Germany 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
See MoreIreland: Finance Ministry delivers the Budget 2022
On 12 October 2021, the Finance Ministry presented Budget 2022, which covers the following tax measures: The new minimum effective corporation tax rate will be 15%. However, Ireland will continue to offer the 12.5% rate for businesses with
See MoreCyprus clarifies bilateral agreement with US on exchange of CbC report
On 7 October 2021, the Cyprus Tax Department informs all legal entities and their representatives that the bilateral Competent Authority Arrangement (CAA) for the exchange of Country-by-Country (CbC Reports) between Cyprus and the United States of
See MoreSpain deposits BEPS MLI ratification instrument
On 28 September 2021, Spain deposited its instrument of ratification for the BEPS MLI. On 7 June 2017, Spain signed this convention and the MLI will enter into force on 1 January 2022 for
See MoreAustria releases the new transfer pricing guideline for 2021
On 7 October 2021, the Austrian Ministry of Finance published the updated Austrian Transfer Pricing Guidelines (Austrian Guidelines) 2021. The Austrian Guidelines 2021 are an essential interpretative aid for the application of the arm’s-length
See MoreSweden proposes the Budget Bill for 2022
On 20 September 2021, the Ministry of Finance has proposed the Budget Bill for 2022. The budget includes the following tax measures: The introduction of a modernized withholding tax on dividends paid to non-residents, including a standard
See MoreFinland: Supreme court makes a decision on arm’s length range and TP adjustment
On 13 September 2021, the Finnish Supreme Administrative Court (SAC) published a decision addressing the use of comparable data and the range of results in calculating transfer pricing adjustments. The case concerned a company, Finnish A Oy,
See MorePoland: Lower chamber of parliament passes the tax reform bill
On 1 October 2021, the lower chamber of parliament (the Sejm) of Poland has passed the 3rd reading the bill for the so-called “Polish Deal” tax reform bill. The bill proposes to several tax reform measures including new minimum corporate tax,
See MorePoland: Government plans to extend the scope of CFC rules
On 8 September 2021, the Polish government submitted a bill to the Parliament including the proposal extending the application of the CFC rules. The proposal includes the following changes: Extension of the definition of a foreign legal entity
See MoreCyprus: MoF further extends the deadline for e-filing return
On 24 September 2021, Cyprus’s Ministry of Finance has issued a decree providing further extension of electronic submission of tax returns for business (TD4) and personal (TD1A) for the fiscal year 2019. The new deadline is 30 November 2021.
See MoreCyprus: Tax Department extends the DAC6 reporting deadlines
On 21 September 2021, the Tax Department of Cyprus has issued a notice extending the DAC6 reporting deadlines. Accordingly, there will be no imposition of administrative fines for overdue submission of DAC6 information that will be submitted until
See MoreUkraine: STS clarifies the controlled transactions criteria for TP purposes
Recently, the State Tax Service (STS) has clarified the criteria for classifying transactions between related parties (Ukrainian residents and non-residents) as controlled for transfer pricing (TP) purposes. Under Ukrainian transfer pricing
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