Serbia: MoF adopts arm’s length interest rates for 2023
On 29 March 2023, the Serbian Ministry of Finance has approved the rulebook on arm’s length interest rates for 2023. The rulebook will be effective from 6 April 2023. Interest rates in accordance with “arm’s-length” principle that applies
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UK enacts Mandatory Disclosure Rules
The OECD Model Mandatory Disclosure Rules (MDR), which require the disclosure of cross-border tax avoidance arrangements, enacted in the UK on 28 March 2023. The MDR imposes an obligation on taxpayers and advisers to provide information to the tax
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Sweden proposes implementation of global minimum tax law
The Ministry of Finance has issued a memorandum containing suggestions and explanations to supplement the preliminary report on the implementation of the EU global minimum tax directive. On 7th February 2023, preliminary report was presented to the
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Russia: Government decide to impose windfall tax on large companies
According to announcement from the Minister of Finance of Russia, an agreement has been reached by the Russian government to impose a windfall tax on big companies operating in Russia. A proposed tax on large company’s excess profits is set to be
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Belarus updates guidance on the taxation of foreign organizations operating through a PE
On 10 March 2023, the Ministry of Taxes and Duties of Belarus issued Guidance Letter No. No.4-2-21/00759 to clarify the taxation of foreign organizations operating in the territory of the Republic of Belarus through permanent establishments (PEs).
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IMF Report looks at Luxembourg’s Economy
On 10 March 2023 the IMF issued a report following consultations with Luxembourg under Article IV of the IMF’s articles of agreement. Luxembourg’s economy has recovered well from the pandemic despite the external challenges in 2022, although
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North Macedonia: Government proposes windfall profits tax on fossil fuel sector
The government has presented a new proposal to the parliament for a temporary solidarity tax (windfall tax) on the fossil fuel industry. Under this proposal, the following key elements have been outlined: Taxable Entities: Companies with
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Switzerland publishes safe harbor interest rates for 2023
The Swiss Federal Tax Administration (SFTA) recently released Circular Letter No. 203 and Circular Letter No. 204 on 7 and 8 February 2023, respectively. These circulars provide safe harbor interest rates for intercompany loans and advances in Swiss
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UK: HMRC publishes guidance on ADR procedure
On 1 February 2023, UK HMRC published Alternative Dispute Resolution (ADR) Guidance with details of an alternative dispute resolution procedure. ADR in HMRC is a flexible process in which an impartial and neutral HMRC mediator actively assists
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IMF Report Considers the Economic Outlook for Malta
On 8 February 2023 the IMF issued a report following discussions with Malta under Article IV of the IMF’s articles of agreement. The economy has recovered from the recession caused by the pandemic with output growing by 11.75% in 2021. Further
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Russia: MoF Clarifies Tax Incentives for IT Sector
On 1 February 2023, the Ministry of Finance (MoF) of Russia published a Guidance Letter 03-03-06/1/5102 clarifying the application of tax incentives in the IT sector, that reducing the corporate income tax rate and social security
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UK: Research on Taxpayer Experience of the Profit Diversion Compliance Facility
On 7 February 2023 HMRC published the results of research commissioned in order to understand taxpayers’ experience of the Profit Diversion Compliance Facility (PDCF) and Diverted Profits enquiry process. The research was conducted through
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Russia: MoF Clarifies Late Payment Interest in 2023
On 27 January 2023, the Ministry of Finance (MoF) of Russia published a Guidance Letter 03-02-07/126954 clarifying the late payment interest applicable in 2023 regarding unpaid taxes. Late payment interest will be applied based on the negative
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Russia updates the list of foreign states for automatic exchange of CbC reports
Recently, the Federal Tax Service of Russia published (Order No. ED-7-17/1226) a new list of foreign states and territories, with which Russia will automatically exchange Country-by-Country (CbC) reports. Accordingly, the following states are
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Albania introduces windfall tax on electricity producers
On 18 January 2023, Albania gazettes Law 98/2022 regarding introduction of a temporary windfall tax on excess income of energy producers. This windfall tax is imposed at a rate 50% on excess income on the sale of electricity at a price above
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Iceland: Tax administration announces deadline for 2022 CbC notification
On 2 January 2023, the Icelandic Directorate of Internal Revenue published Notice 1609/2022, announcing the Jan. 31 deadline for submitting country-by-country (CbC) reporting for the fiscal year 2022. The notice contains that the notification must
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Belarus issues law on various tax amendment
On 4 January 2023, Belarus published Law No. 230-Z in the Official Gazette amending various tax measures. The following are the key amendments to the tax code: From 1 January 2023, the deadline for submitting transfer pricing documentation to
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North Macedonia proposes amendments to TP reporting
Proposed amendments to the corporate income tax law regarding transfer pricing reporting would become effective from 1 January 2023. The proposed amendments include following changes: the requirement to submit a transfer pricing (TP) report to
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