Greece: Government introduces new rules for interest deduction restriction
On 28 March 2022, Government published Law No. 4916/2022, which establishes new group escape rules for the 30% of EBITDA interest deduction restriction. The new group scape rule was made optional when the Greek interest restriction rules were
See MoreCyprus: Tax department publishes FAQs on DAC6 reporting
On 8 April 2022, the Tax Department of Cyprus has posted online Frequently Asked Questions (FAQs) regarding reportable cross-border tax arrangements (DAC6). The FAQs are currently available in Greek language and covered following
See MorePoland: MOF launches public consultations for TP method on resale price
On 4 April 2022, the Polish Ministry of Finance launched a public consultation on draft guidelines clarifying the resale pricing method for determining the arm's length value of transactions between associated parties. The guidance clarifies,
See MoreEU: Pressure on member states to revise CBI/RBI schemes
Recently there has been increased pressure on European Union (EU) member states to scale back their schemes offering citizenship or residence in return for financial contributions. This reflects heightened security concerns in view of the current
See MoreLuxembourg: Tax Authority updates guidance on interest deduction limitation
On 25 March 2022, the Luxembourg Tax Authority updated Circular L.I.R. n° 168bis/1 (French) which clarifies certain aspects of the interest expense deduction limitation rules included in article 168bis of the Luxembourg Income Tax Law (ITL).
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Ireland: Revenue issues an eBrief regarding DAC6
On 1 April 2022, the Revenue published an eBrief No. 078/22, which updates a manual regarding mandatory disclosure of reportable cross-border arrangements (DAC6). This was introduced by Finance Act 2021 and to provide additional guidance on the
See MorePoland: MOF extends the CIT return submission deadline for 2021
On 26 March 2022, the Polish Minister of Finance has signed an ordinance providing the extension of the deadline for the submission of corporate income tax returns for 2021. The deadline for the submission of corporate tax returns and the payment
See MoreThailand deposits BEPS MLI ratification instrument
On 31 March 2022, Thailand has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Convention or MLI), which now covers over 1800 bilateral
See MorePoland: MOF extends the deadline for APA implementation report
On 23 March 2022, the Polish Ministry of Finance has published a press release extending the deadline for APA implementation report to 30 June 2022. The deadline extension applies to companies with financial years ending between 1 December 2021 and
See MorePoland: MOF publishes further increases in late payment interest for tax arrears
On 11 March 2022, the Polish Ministry of Finance second time published the increased interest rates on tax arrears as well as on the late payment of tax, tax advances, or social security contributions. Accordingly, the standard rate is increased
See MoreLuxembourg: MOF introduces a new Bill to the Parliament on ATAD
On 9 March 2022, the Luxembourg Ministry of Finance introduced a new Bill 7974 to the Parliament to amend the current interest deduction limitation rules under the EU Anti-Tax Avoidance Directive (ATAD). The Bill excludes ‘EU
See MoreSweden Updates CbC reporting guideline
On 14 March 2022, the Swedish Tax Agency updated the country-by-country reporting (CbC) guidelines for multinational companies (MNEs). The guidelines introduced the following updates: 1) Annual notification requirements for Swedish
See MoreSweden: Administrative court rules in favor of the taxpayer in TP case
On 28 February 2022, the Swedish Administrative Court announced its ruling and have supported Pandox AB claim in the company’s dispute with the Swedish Tax Agency. Pandox is a chain company owning around 157 hotel properties in 15
See MoreSpain adopts ATAD2 anti-hybrid rules
On 9 March 2022, Spanish government amended the Corporate Income Tax (CIT) law and the Non-Resident Income Tax (NRIT) law to address hybrid mismatches. The purpose of these amendments is to enact into Spanish domestic law the anti-hybrid rules
See MoreMalta changes the interest rate on unpaid tax and additional tax rate
On 4 March 2022, Malta issued Legal Notice 99 of 2022 in the Official Gazette, through which Malta changes the interest rate on unpaid tax and additional tax rate. The Legal Notice provides the following changes: the additional tax shall be
See MoreNetherlands: Covid-19 support measures will end in the second quarter of 2022
The Dutch government has published a notice declaring the key support measures implemented and subsequently extended in response to the Covid-19 pandemic will end with effect from 1 April 2022. The measures contain the fixed costs grant scheme
See MoreEU: Joint European Action for Affordable and Sustainable Energy
On 8 March 2022 the European Commission issued a communication entitled REPowerEU: Joint European Action for more affordable, secure and sustainable energy. This document notes that the current geopolitical situation requires independence from
See MoreGreece: AADE issues a Circular to provide guidance on CFC rules
On 23 February 2022, the Greek Public Revenue Authority (AADE) published Circular E. 2018 of 23 February 2022, providing guidance on the application of Controlled Foreign Companies (CFC rules). This is introduced as from 1 January 2019 in line with
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