French Court of Appeal of Paris clarifies TP rules for cross-border group companies
Recently, the French Court of Appeal of Paris issued a decision in the case of France v. Ferragamo France (No. 20PA0360), in June 2022, explaining the transfer pricing (TP) rules for cross-border group companies. The taxpayer (Ferragamo France),
See More
Hungary gazettes the 2023 Budget bill including transfer pricing changes
On 27 July 2022, the Hungarian Official Gazette published the Budget Bill (Law XXIV of 2022) providing for amendments to the Hungarian transfer pricing regulations. The law was passed by the parliament on 19 July 2022. The law includes the following
See More
Ireland provides guidance on the tax deductibility of DSTs
On 5 August 2022, the Irish Revenue published an eBrief No. 158/22 on Tax and Duty Manual Part 04-06-03 that provides guidance on the tax deductibility of Digital Services Taxes (DSTs). The purpose of this manual is to outline the rules in relation
See More
Cyprus increases the deduction for research and development related cost
On 20 July 2022, the Cypriot Official Gazette published the amended income tax law increasing the deduction for research and development (R&D) expenses for the years 2022, 2023 and 2024. The changes are provided under the amendment of Article 9
See More
Hungary: Parliament adopts a bill imposing additional requirement for TPD
On 19 July 2022, the Hungarian Parliament passed a bill introducing important changes to the transfer pricing rules. The law introduces a significant additional reporting requirement for intra-group transactions and requires transfer pricing
See More
Belgium plans for tax cut
On 18 July 2022, Mr. Vincent Van Peteghem, the Finance Minister of Belgium declared plans for broad tax reforms. Some of the key reform measures include: Increasing the tax-exempt amount for individual income tax from EUR 9,270 to EUR 13,390,
See More
Germany enacts the bill on the interest rate for late payment
On 21 July 2022, The Ministry of Finance published the bill providing for a reduced rate for late interest payments on excess payments and refunds of tax in the Official Gazette. The bill had been previously approved by the lower house of the
See More
Netherlands publishes new transfer pricing decree
On 1 July 2022, the Netherlands Ministry of Finance issued Decree No. 2022-0000139020 related to the application of the arm's length principle and the OECD transfer pricing guidelines. The New Decree replaces the previous transfer pricing (TP)
See MoreGreece publishes lists of Jurisdictions for Automatic Exchange of Information on CbC reporting
Recently, the Ministry of Finance published a decision containing the list of jurisdictions to which it will apply the OECD Agreement on the Automatic Exchange of Information on Country-by-Country Reporting (CbC) (2016) in 2022 concerning the
See More
Portugal extends the deadline to submit the TP file
On 6 July 2022, the government announced that it would extend the transfer pricing (TP) deadlines for preparation and/or submission to the tax authority. The deadline is extended from 15 July to 15 September 2022 without any accruals or
See More
Cyprus: Parliament adopts new transfer pricing legislation
On 30 June 2022, the Cyprus House of Representatives enacted detailed transfer pricing legislation amending the Cyprus Income Tax Law (ITL) and the issuance of Regulations. The amendment includes the new TP documentation requirements and a framework
See More
Poland: MoF proposes important amendments to corporate income tax law
On 28 June 2022, the Polish government announced a draft law to proposing significant changes to the Polish Corporate Income Tax Act. The proposed changes impact the following areas; The effective date of the new “minimum tax” will be
See More
Lithuania amends the APA rules
Recently, the State Tax Inspectorate of the Ministry of Finance of the Republic of Lithuania revised the Lithuanian Advance Pricing Agreements (APAs), which came into effect on 31 March 2022. Among other changes, the amendments also provide for
See More
Germany: MoF publishes a draft decree-law regarding the transfer of functions
On 5 July 2022, the German Federal Ministry of Finance published a draft decree-law regarding the transfer of functions. The aim of the draft decree-law is to adapt and restructure the existing regulations on the arm's length principle with the
See More
Ireland: Revenue issues eBrief on anti-hybrid rules guidance
On 29 June 2022, the Irish Revenue published an eBrief No. 137/22 to announce a manual to update the guidance on anti-hybrid rules. Accordingly, Tax and Duty Manual Part 35C-00-01 - Guidance on the Anti-hybrid rules - has been updated for
See MoreGreece enacts ATAD’s reverse hybrid rule
On 30 June 2022, the government of Greece enacted legislation implementing ATAD's reverse hybrid rule with retroactive effect from 1 January 2022. The rule does not apply to collective investment vehicles. The new rule applies to situations where
See MoreSpain confirms the completion of its internal procedures for the entry into force of the MLI
On 28 June 2022 OECD published the update status of signatory countries regarding BEPS MLI. Accordingly, on 1 June 2022, Spain submitted its notification confirming the completion of its internal procedures for the entry into force of the
See MorePoland: MoF extends the filing deadline for corporate income tax return
On 22 June 2022, the Polish Ministry of Finance has published a draft decree extending the deadline for submitting the CIT-8E return. Accordingly, the deadline for submitting the CIT-8E return is 30 September 2022. The extension applies to all
See More