MLI enters into force for Hungary
On 1 July 2021, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Hungary. The agreement has come to into effect from the first day of the fourth month
See MoreIreland: Government declares a second feedback statement on ATAD interest limitation rule
On 2 July 2021, the Finance Minister, Paschal Donohoe TD, launched a second Feedback Statement on transposition of the ATAD interest limitation ratio. The Anti-Tax Avoidance Directive (ATAD) requires Member States to introduce an interest
See MoreIreland: Finance Ministry declares for a feedback statement on ATAD anti-hybrid rule
On 2 July 2021, the Finance Minister, Paschal Donohoe TD, launched a Feedback Statement on the Anti-reverse hybrid rule. The anti-hybrid rules are largely contained in ATAD2, which extended the basic anti-hybrid provisions of the first ATAD and
See MoreDenmark: OECD publishes latest MLI position on arbitration reservation
On 29 June 2021, the OECD published a document, which contains the consolidated list of reservations and notifications made by the Kingdom of Denmark upon deposit of the instrument of ratification pursuant to Articles 28(5) and 29(1) of the
See MoreDenmark: Parliament approves ATAD amendments to CFC rules
On 3 June 2021, the Danish Parliament approved a Bill L 89 to amend the controlled foreign company (CFC) rules with the purpose of bringing them in line with the EU Anti-Tax Avoidance Directive (ATAD). The major mechanism in the Danish CFC rules
See MorePoland: MOF announces a proposal to change the transfer pricing regulation
On 28 June 2021, Poland Ministry of Finance issued a plans for taxpayer-friendly amendments to the transfer pricing regulations. The following measures have been proposed under this plan. Cancellation on the preparation of transfer pricing
See MorePoland: MOF further defers the WHT collection system to 31 December 2021
On 25 June 2021, the Polish Ministry of Finance has published a decree providing further postponed the introduction of the withholding tax pay and refund system until 31 December 2021. The obligation was originally deferred until the end of June
See MoreCroatia: BEPS MLI enters into force
On 29 June 2021, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, the MLI enters into
See MorePoland: MOF announces tax measures to attract foreign investment
On 14 June 2021, the Polish Ministry of Finance announced a new package of measures to encourage foreign investment in Poland. Accordingly, 95% tax exemption for dividends received by Polish holding companies after a one-year holding period,
See MoreSpain publishes an order on tax return in relation to DST
On 11 June 2021, Spain published the form 490 for the digital services tax that was approved on 9 June 2021. In this declaration, taxpayers must indicate the group to which they belong, their total income, if any, and the tax base by category of
See MoreFrance: Government presents draft Finance Bill 2021 in the National Assembly
On 2 June 2021, Government published the amended draft Finance Bill 2021 in the National Assembly, which proposes to temporally ease conditions related to the carryback mechanism applicable to tax losses. According to the Bill, companies will be
See MoreSpain publishes a decree amending Mutual Agreement Procedure (MAP)
On 8 June 2021, the Spanish government has published a Royal Decree 399/2021 which amends the Regulation on Mutual Agreement Procedures (MAP) as approved by Royal Decree 1794/2008. The decree implements three packages of initiatives to enhance
See MoreCyprus: Tax department issues a notice extending penalty relief for DAC6 reporting
On 3 June 2021, the Cyprus tax department has issued a notice providing an extension to the imposition of administrative fines for overdue submission of DAC6 reporting. The Tax Department informs that there will be no imposition of
See MoreAustria: Government publishes a Decree regarding late payment interest
On 4 June 2021, the Government published a Decree of 4 June 2021 providing the updates regarding late payment interest, suspended tax payment and others. According to the update, from 1st July 2021 to 30 June 2024, interest rate for late corporate
See MoreIreland: Revenue updates a guidance on surcharge on undistributed income
On 10 June 2021, the Irish Revenue published an eBrief 114/21 and a manual regarding updated guidance on the surcharge on undistributed income of service companies. Section 441 Taxes Consolidation Act 1997 provides for an additional charge of
See MoreGreece: Government publishes a Law to introduce new tax provisions
On 18 May 2021, the Government Officially published Law 4799/2021, introducing income tax reductions and other amendments to the Greek Income Tax Code. The Act includes some of the following provisions: Transfer pricing Enterprises
See MoreNetherlands updates loss carry forward provision
On 4 June 2021, the Netherlands published the Decree of 21 May 2021 in the Official Gazette, which provides for the implementation of the net operating loss carry forward changes. This legislation will enter into force for fiscal years on or after
See MoreFinnish Supreme Administrative Court makes a decision in a transfer pricing case
On 2 June 2021, the Finnish Supreme Administrative Court issued a decision regarding the acceptability of U.S. GAAP accounting standards as a basis for transfer pricing. Background The case concerned a Finnish company owned by a low-risk
See More