Russia increases the Interest rate from July 2021
On 23 July 2021, the Russian Central Bank announced the decision to increase the key rate from 5.5% to 6.5% with effect from 26 July 2021. For tax purposes, the key rate is important in relation to the safe harbor rates for interest income and
See MoreUkraine: STS releases guidance letter on tax treaty requirements under CFC rules
On 12 July 2021, the State Tax Service (STS) has issued a guidance letter 2712/IPK/ 99-00-21-02-02-06 which clarifies tax treaty requirements under CFC rules. The guidance letter clarifies that from 1 January 2022 CFC profits may be exempt from
See MoreUkraine: National Bank increases the interest rate from July 2021
On 22 July 2021, the National Bank of Ukraine has decided to increase its key policy rate from 7.5% to 8% per annum with effect from 23 July 2021. The interest rate has a tax effect on the late tax payment interest and
See MoreUkraine issues draft laws on tax incentives for industrial park
Ukraine has issued Draft Law 5688 on 22 June 2021, and Draft Law 5688-1 on 7 July 2021 ‘on Amendments to the Tax Code of Ukraine to create favorable conditions for attracting large-scale investment in the industrial park’. The Draft Law
See MoreIceland publishes a law on new penalties for transfer pricing documentation
On 15 June 2021, Iceland published Law 61/2021 in the Official Gazette introducing new rules for the imposition of fines on taxpayers who fail to comply with transfer pricing documentation requirements for related party transactions, whether
See MoreEU: Annual Report on Taxation 2021
On 18 May 2021 the European Union (EU) published the Annual Report on Taxation 2021 assessing progress made by EU Member States in aligning their tax policies with the EU’s tax priorities to promote innovation and productivity, encourage
See MoreEU: European Commission sets out future agenda for business taxation
On 18 May 2021 the European Commission adopted a Communication on Business Taxation for the 21st Century setting out its vision for supporting business during the economic recovery and achieving fairer taxation. Ensuring effective
See MoreBelarus: Tax and Duties Ministry clarifies the taxation of PEs in Belarus
On 29 April 2021, the Tax and Duties Ministry of the Republic of Belarus has issued Guidance Letter No. 4-2-15/00981 to clarify the taxation of foreign organizations operating in the territory of the Republic of Belarus through permanent
See MoreUkraine: National Bank increases the interest rate from April 2021
On 15 April 2021, the National Bank of Ukraine has decided to increase its key policy rate from 6.5% to 7.5% per annum with effect from 16 April 2021. The interest rate has a tax effect on the late tax payment interest and
See MoreSerbia: MOF releases arm’s length interest rates for 2021
On 19 March 2021, the Serbian Ministry of Finance has published the Rulebook on Arm’s Length Interest Rates applicable for 2021 that applies on related parties’ loans. Rulebook comes into force on 27 March 2021. Taxpayers can use
See MoreUkraine: National Bank increases the interest rate from March 2021
On 4 March 2021, the National Bank of Ukraine has decided to increase its key policy rate from 6% to 6.5% per annum with effect from 5 March 2021. The interest rate has a tax effect on the late tax payment interest and
See MoreGeorgia: 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 More