France: 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 MorePoland: MOF announces a draft law introducing new advertising tax
On 2 February 2021, the Polish Government issued a draft introducing a new advertising tax (premium) on digital (internet) advertising and conventional advertising. The online advertising premium rate will be 5%. It will apply to advertisers whose
See MoreGreece publishes a Law for the ratification of BEPS MLI
On 26 January 2021, the Government Officially published Law No. 4768 to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Greece must now deposit its ratification
See MoreIreland: Revenue issues eBrief regarding DAC6 reporting obligations
On 27 January 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 where certain
See MoreGreece: Revenue authority extends the DAC6 reporting submission deadline
On 27 January 2021, the Greek Public Revenue Authority (AADE) published Circular A. 1017 of 27 January 2021 regarding the delay of the initial reporting obligations for DAC6 cross-border arrangement. Under the Circular, the 30-day reporting period
See MoreLuxembourg Parliament approves Bill on the deduction of interest and royalties expenses
On 28 January 2021, the Luxembourg Parliament has approved Bill No. 7547 introducing a non-deductibility of interest or royalties paid to associate enterprises established in countries that are “blacklisted” as being “non-cooperative” for
See MoreBelgium postpones DAC6 reporting deadline
On 28 January 2021, the Belgian Ministry of Finance has declared that due to the Covid-19 pandemic the Belgian tax authority will be postponing its reporting deadline without late submission penalties. The reporting deadline for historical
See MoreLuxembourg updates the list of jurisdictions for exchanging CbC reports
On 26 January 2021, the Luxembourg Ministry of Finance published Grand-Ducal Regulation of 22 January 2021 in the Official Gazette amending Grand-Ducal Regulation of 13 February 2018. The Regulation updates the list of jurisdictions for
See MoreSweden applies the so-called “Sunday rule” for DAC6 reporting deadlines
Recently, the Swedish Tax Agency has updated guidance on reportable arrangements (DAC6) reporting deadlines. The Tax Agency confirms that the so-called “Sunday rule” applies for DAC6 reporting deadlines. If the reporting deadline falls on a
See More