Spain: Council of Ministers adopts Royal-Decree implementing the reverse hybrid rules
On 18 October 2022, the Spanish Council of Ministers approved the Royal Decree-Law (RDL) implementing the reverse hybrid rules under the Anti-Tax Avoidance Directive 2017/952 (ATAD-2). The law generally aims to combat tax avoidance as a result of a
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Austria plans to expand the application on existing treaties under BEPS MLI
On 30 November 2022, the Austrian Council of Ministers approved the extension of the application on existing tax treaties under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting
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Portugal: Parliament approves budget for 2023
On 25 November 2022, the Portuguese parliament approved the Budget for 2023. This budget includes the following corporate tax measures: Changes in current tax loss carry forward rules for corporate income tax (CIT). Along with other things, tax
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Ireland proposes windfall profit tax in the energy sector
On 22 November, the Irish Minister for the Environment, Climate and Communications, Eamon Ryan announced measures to address windfall gains in the energy sector through the implementation of Council Regulation (EU) 2022/1854. Elevated wholesale
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Ireland explains non-resident corporate landlords within the charge to corporation tax
On 21 November 2022, the Irish Revenue published eBrief No. 199/22 clarifying that corporate landlords are subject to corporation tax rather than income tax on Irish rental income from 1 January 2022. Accordingly, the following Tax and Duty Manuals
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Italy approves draft Budget for 2023
On 21 November 2022, Italian Council of Ministers approved the State Budget for 2023 along with the multi-year budget for 2023 to 2025. The budget increasing the tax credits for the purchase of natural gas and electricity through March 2023 and
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Germany publishes a draft bill updating list of participating jurisdictions under MCAA-CbC
On 23 November 2023, the German Ministry of Finance published a draft bill providing an updated list of jurisdictions participating under the Multilateral Competent Authority Agreement (MCAA) on the exchange of CbC reports. Accordingly, Germany will
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Finnish: Parliament adopts a draft bill of new mining tax
On 18 November 2022, the Finnish Parliament has approved a draft bill which proposes the implementation of royalty-type taxes on minerals extracted in Finland. The draft bill proposed a royalty of 0.6% to be imposed on the taxable value of a
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Malta implements formal transfer pricing rules
On 18 November 2022, Malta published Legal Notice 284 of 2022 in the Official Gazette implementing transfer pricing rules into Malta’s tax code. These rules shall apply for basis years commencing on or after 1 January 2024 in relation to any
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Greece introduces simplifies tax refund procedure for legal entities
On 14 November 2022, the Greek Public Revenue Authority (AADE) published Decision A. 1160 in the Official Gazette regarding the simplified income tax refund procedures for legal entities. Accordingly, if entities file their corporate income tax
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Belgium: Parliament approves amendments on statute of limitations
On 10 November 2022, the Belgian parliament approved the law amending the statutes of limitations periods. The statute of limitations periods is set as follows: A standard 3-year statute of limitations where a return has been timely filed.
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Bulgaria proposes a temporary solidarity contribution to the fossil sector
On 1 November 2022, the Government of Bulgaria submitted a draft bill to the Parliament regarding a temporary solidarity contribution of 33% on oil, gas and coal companies in line with the Council Regulation (EU) 2022/1854 of 6 October 2022 on an
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Germany: Federal Cabinet approves CbC reports exchange agreement with US
On 4 November 2022, the German Upper House of Parliament (Bundesrat) approves bill No. 567/22 for consideration to ratify the competent authority agreement (CAA) on the exchange of country-by-country (CbC) reports with the US. The competent
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Poland: President signs the Polish Deal 3.0 including transfer pricing changes
On 21 October 2022, the President of Poland signed the Law of 7 October 2022 amending the Corporate Income Tax Act (referred to as Polish Deal 3.0), including certain transfer pricing changes. One of the most significant changes to transfer pricing
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Denmark issues guidance on DAC7 reporting requirements
On 2 November 2022, the Danish Customs and Tax Administration published guidance on DAC7 registration and reporting requirements for digital platform operators under Council Directive (EU) 2021/514. This directive has been published on 25 March
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Belgium declares tax payment deferral due to energy crisis
On 28 October 2022, Belgium's Federal Public Service (SPF) Finance has declared a general deferral of tax payments of personal income tax, corporate tax, and non-resident tax for tax year 2022. The tax payment deadline is extended from the
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Hungary submits a draft legislation to Parliament on APA and CbCR
On 18 October 2022, Hungarian Ministry of Finance has submitted a draft legislation to the Parliament proposing the amendments of advance pricing arrangements (APAs) and introduction of public CbC reporting. Effective from 1 January 2023, the
See MoreEstonia: Government approves Law on DAC7
On 20 October 2022, the Estonian Government approved Law regarding new reporting obligations Council Directive (EU) 2021/514 for digital platform operators (DAC7) into domestic law. This directive has been published on 25 March 2021, entered into
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