Georgia: MOF publishes decree amending transfer pricing rules for APAs
On 2 March 2021, the Georgian Ministry of Finance published Decree No.45 amending the Georgian transfer pricing rules regarding the Unilateral Advance Pricing Agreement (APA). The decree amends the APA clauses, most importantly reducing the filing
See MoreUkraine: MOF approves the procedure for submitting CbC report
On 19 February 2021, the Ukrainian Ministry of Finance (MOF) has issued a press release where they clarify the procedure for submitting Country-by-Country (CbC) report. The Order of the Ministry of Finance No. 764 dated 14 December 2020, which
See MoreJapan and Georgia enter into tax pact
On 29 January 2021, “Convention between Japan and Georgia for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance” (hereinafter referred to as the New Convention) was signed in
See MoreSwitzerland declares safe harbor interest rates
The Federal Tax Administration of Switzerland has published two separate circulars regarding safe harbor interest rate limits applicable to shareholder and related party loans in 2021. The rates may vary depend on whether the financing is in Swiss
See MoreSwitzerland: Review on international financial and tax matters of 2020
Switzerland’s Secretariat for International Finance (SIF) has published its annual review on international financial and tax matters for 2020. With respect to tax-related matters in particular, the review includes the following: Taxing
See MoreSerbia: Ministry of Finance adopts Rulebooks concerning CIT amendments
On 30 December 2020, the Rulebooks (as the regulations are referred to in Serbia) regarding corporate income tax amendments published in the official gazette. The Rulebooks are effective retroactively for tax periods starting in 2020 including
See MoreRussia updates mandatory audit thresholds
On 29 December 2020, Russia has published Federal Law No 476-FZ which amended the thresholds for mandatory tax audit with effect from 1 January 2021. The Federal Law increased the turnover threshold in the previous year to RUB 800 million
See MoreSerbia publishes decree providing defer payment of taxes and contributions
On 25 December 2020, the Decree of Serbia No.156 was published in the Official gazette providing guidance concerning the method for paying amounts of taxes deferred in response to coronavirus (COVID-19) pandemic. Accordingly, whole amount of
See MoreRussia declares country names for exchange of CbC Report
On 10 December 2020, Russia has published an order of the Federal Tax Service amending the list of Territories and States with which Russia will automatically exchange Country-by-Country (CbC) reports. The Order entered into force on 21
See MoreRussia declares tax relief measures for SME sector
On 12 November 2020, in response to Covid-19 pandemic the Government of Russia has declared the issuance of Decree No. 1791, which extends certain tax relief measures related to SME sector. The relief measures include the deferral of advance
See MoreSwitzerland: Federal Council adopts dispatch on Federal Act on implementation of international tax agreements
On 4 November 2020, the Swiss Federal Council adopted the dispatch on the Federal Act on the implementation of international tax agreements. With this proposal, the Federal Council is adapting the existing law to the changes made to international
See MoreSwitzerland declares interest rates for 2021
The Federal Tax Administration of Switzerland has published Circular Letter 2-185-D-2020-f of 22 October 2020 declaring federal direct tax interest rates for the 2021 calendar year. According to the Circular letter, Federal Department of Finance
See MoreAustria signs MAP agreement with Sweden
On 16 October 2020, the Finance Ministry of Austria announced that Austria signed an agreement regarding the implementation of agreements concluded on the basis of Article 22 (Mutual Agreement Procedure) with Sweden. The agreement effects from 6
See MoreUkraine: MOF develops a regulatory framework for the execution of the BEPS
On 20 October 2020, the Ukrainian Ministry of Finance (MOF) has issued a press release regarding Implementation of the Law No 466 in Part of the BEPS Plan. MOF stated that they will approve all necessary regulations on the implementation of the
See MoreBelarus is set to join the Inclusive Framework on BEPS
On 14 October 2020, Belarus has published Resolution No. 590 on the National Legal Internet Portal, through which Belarus is set to join the Global Forum on Transparency and Exchange of Information for Tax Purposes. The decision was formalized in
See MoreNorth Macedonia declares Fourth round of tax relief measures amid Covid-19 outbreak
On 24 September 2020, the Ministry of Finance has issued a release announcing the adoption of the fourth round of relief measures in response to the Covid-19 pandemic. The key tax measures are following: The reduction of interest rate
See MoreHong Kong and Georgia enter into tax pact
On 5 October 2020, the Secretary for Financial Services and the Treasury, Mr Christopher Hui, on behalf of the Hong Kong Special Administrative Region Government, signed a comprehensive avoidance of double taxation agreement (CDTA) with
See MoreRussia and Malta sign a protocol to amend the double tax treaty
On 1 October, the Russian Ministry of Finance reported that the Protocol to Russia - Malta DTT has been signed. In general dividend and interest WHT increases to 15%. However, there is a number of exceptions and in some cases current 5% dividend
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