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Issue 62 - May 2022
CAMBODIA - New law aims to attract investors
CANADA - CRA position on income tax implications of cryptocurrency transactions
CANADA - Highlights of 2022 budget measures affecting businesses
CHILE - U.S. tax treaty ratification moves forward
ESTONIA - Agreement reached to postpone Estonia’s implementation of the global minimum tax
EUROPEAN UNION - Draft directive aims to reduce bias that favours debt financing
GERMANY - Expanded reporting obligations for German entities affect ultimate beneficial owners
INTERNATIONAL - Corporate tax bytes
KUWAIT - Income tax on Kuwait-registered branches of GCC banks proposed
LUXEMBOURG - Capital contribution without share issuance does not increase acquisition price for pur
OECD - Impact of the OECD Pillar Two model rules on natural resource companies
OECD - Pillar Two rules could have lasting impact on MNE groups
SPAIN - Interaction of new minimum tax with Pillar Two and summary of White Paper on international t
UGANDA - Definition of beneficial ownership may be expanded
UNITED ARAB EMIRATES - Ministry of Finance launches public consultation on proposed corporate tax re
UNITED STATES - FY 2023 budget plan proposals affecting corporate businesses
UNITED STATES - Important cryptocurrency related proposals included in 2023 budget proposal
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Indirect Tax News
Issue 2-2022
BAHRAIN - Guidance issued on VAT treatment of cryptocurrency transactions
CHINA - Input VAT refund policy expanded
CZECH REPUBLIC - Guidance issued on the VAT treatment of cryptocurrency transactions
EUROPEAN UNION - Commission proposes solution to address double VAT on distance sales of goods from
EUROPEAN UNION - EU Finance Ministers approve new VAT rates directive
INTERNATIONAL - Indirect tax bytes
ITALY - New VAT rule for credit notes in insolvency proceedings
NETHERLANDS - Foreign entrepreneurs using OSS need not appoint tax representative
SINGAPORE - GST increase postponed and will be phased in
SLOVENIA - New rules for VAT registration of non-resident suppliers, higher registration threshold a
SPAIN - Ruling issued on VAT treatment of cryptocurrency platform transactions
UNITED ARAB EMIRATES - Updates on VAT rules
UNITED STATES - Sales tax issues with crypto transactions
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GES News
May 2022 Issue
HONG KONG - Will COVID-19 affect the anticipated changes to the legal limit for claiming unpaid wage
PORTUGAL -Non-habitual resident in Portugal
UNITED KINGDOM - Employment tax update - points to watch in 2022/23
UNITED KINGDOM - Transaction and retention bonuses - ensuring good value for your spend
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Transfer Pricing News
Issue 38 - March 2022
AUSTRALIA - Patent box legislation introduced
MEXICO - Transfer pricing law changes enter into effect
OECD - Draft model rules on Amount A of Pillar One released for public consultation
OECD - New edition of transfer pricing guidelines issued
PORTUGAL - New transfer pricing rules and documentation requirements enter into effect
INTERNATIONAL - Transfer pricing bytes
UNITED STATES - State transfer pricing takes center stage
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Issue 38 - March 2022
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INTERNATIONAL - Transfer pricing bytes
INTERNATIONAL
Transfer Pricing News Issue 38 - March 2022
Transfer pricing bytes
Australia:
The government
announced
that it will review the advance pricing arrangement (APA) program in 2022, to focus on whether APAs continue to provide the right service for taxpayers. As part of the review, the tax authorities will consider how to tailor the APA process to better align to risk and taxpayer behavioural indicators. The review is expected to commence in early 2022 and will include a public consultation process.
Cyprus:
On 24 January 2022, the Cyprus tax authorities issued a set of 14 “
Frequently Asked Questions
” regarding the tax treatment of intragroup back-to-back financing transactions, as set out in an Interpretive Circular dated 30 June 2017. The answers to the FAQs are applicable to all transactions that fall within the scope of the back-to-back circular and relate to loan agreements concluded as of the date of issue of the FAQs, as well as to those loan agreements that were concluded prior to that date that have not been examined by the Tax Department.
Malta
: Malta’s Commissioner for Revenue sought feedback regarding
draft transfer pricing rules
that would implement legislation prescribing the application of the arm’s length principle to the pricing of transactions between associated enterprises that fall within the scope of the rules. The draft rules also include an APA program. The Commissioner invited interested parties to provide general tax policy comments in the area of transfer pricing, as well as specific views on the draft rules and possible alternative approaches. The consultation period ran through 28 February 2022, and the final transfer pricing rules are expected to be published during the last quarter of 2022.
OECD
: The OECD on 28 February 2022 released the third batch of 2021/2022 updates to the
transfer pricing country profiles
of 28 jurisdictions, including Brazil, Canada, China, the UK and the U.S.. This release also includes new chapters for six countries -- Honduras, Iceland, Jamaica, Papua New Guinea, Senegal and Ukraine -- bringing the total number of countries covered to 91. The updated country profiles add new information on countries’ legislations and practices regarding the transfer pricing aspects of financial transactions and the application of the Authorised OECD Approach (AOA) on the attribution of profits to permanent establishments.
South Africa
: The South Africa Revenue Service (SARS) on 11 February 2022 issued a
draft interpretation note
on intragroup loans for public comment, which must be submitted by 29 April 2022. SARS had previously issued similar draft notes in 2013 and 2017, but those drafts were never finalized. The new draft reflects changes in transfer pricing legislation and includes additional detail and new sections. The draft also takes into account the OECD’s Transfer Pricing Guidance on Financial Transactions released in 2020.
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