AngolaDocumentation-Requirement: On 15 March 2022, the Ministry of Finance of Angola has issued Order No. 1083/22 through which the list of the large taxpayers has been revised subject to the preparation of transfer pricing (TP) documentation.
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ArmeniaCompliance with BEPS standards: On 24 March 2022, the Armenian Cabinet approved the ratification of BEPS MLI. Armenia signed the convention on 7 June 2017. After completing the ratification process Armenia must deposit its ratification instrument to bring the MLI into force for its concluded DTAs.
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Hong KongCbC reporting requirement-Deadlines: On 18 March 2022, the Inland Revenue Department issued a press release announcing an extension of the CbC notification deadline, provided that the notification is received via the CbC Reporting Portal on or before 1 June 2022.
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JordanTransfer pricing information return: Recently, the Jordan Income and Sales Tax Department (ISTD) has published new transfer pricing and country-by-country (CbC) Notification forms (Arabic language) in line with executive instructions No. 3 of 16 September 2021.
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LuxembourgRestriction on interest deduction: 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).
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PolandFiling deadlines: 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 of tax is extended to 30 June 2022.
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APAs-General rules: On 23 March 2022, the Polish Ministry of Finance has 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 28 February 2022.
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RomaniaCompliance with BEPS standards: On 28 February 2022, Romania has deposited its instrument of approval or ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Convention or MLI). For Romania, the Convention will enter into force on 1 June 2022.
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RussiaScope of transfer pricing rules: On 22 March 2022, the Russian Parliament amended the criteria for controlled transactions for transfer pricing purposes. Accordingly, the general transaction threshold for transactions to be considered controlled transactions will be raised from RUB 60 million to RUB 120 million per calendar year.
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SpainSpecial rules for hybrid instruments or entities: 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 provisions of hybrid rules entered into force on 11 March 2021, although their effects are applicable to the tax periods that started on or after 1 January 2020.
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SwedenCbC reporting requirement-General rule: On 14 March 2022, the Swedish Tax Agency updated the country-by-country reporting (CbC) guidelines for multinational companies (MNEs). The guidelines include the guidance on CbC electronic reporting through XML schema files.
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ThailandCompliance with BEPS standards: 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). The Convention will enter into force on 1 July 2022 for Thailand. 
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Transfer pricing information return: On 25 March 2022, in response to the COVID-19 pandemic, the Thai Minister of Finance has announced an extension the deadline for filing the transfer pricing disclosure form to 30 May 2022 for the fiscal years starting on or after 1 January 2020 to 31 December 2020.
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USMain corporate income tax rate: On 28 March 2022, the Treasury Department of United States published details of tax proposals in the administration’s budget recommendations for FY 2023 in the “GreenBook”. The proposal includes to raise the corporate income tax rate from 21 percent to 28 percent.
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