Colombia

Documentation/CbC reporting/Master file/Local file: On 20 December 2021, the Colombian Ministry of Finance and Public Credit has issued Decree 1778 specifying the deadlines for transfer pricing (TP) documentation, including local/master file and CbC reports. The deadline for informative transfer pricing returns and Local files is 7 September to 20 September 2022. The deadline for CbC reports is between 12 December to 26 December 2022, and the Master file is between 12 December to 23 December 2022.
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Croatia

Financial transactions-General: The Ministry of Finance announced a new interest rate of 2.68% on loans between related parties for 2022. Accordingly, the interest is calculated at the rate of 2.68% of the minimum required tax revenue for 2022 when a domestic company gives a loan to a foreign affiliate.
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Cyprus

Financial transactions-General: On 24 January 2022, the Cyprus Tax Department published a new “Frequently Asked Questions (FAQs)” section on its website on Transfer Pricing (TP). The FAQs relate to the Interpretative Circular 3 issued on 30 June 2017 (Back-to-Back Circular). The Back to Back Circular applies to both cross-border transactions and domestic transactions between related companies.
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Czech Republic

Information exchange-Multilateral: On 20 January 2022, the Finance Ministry published Finance Bulletin No.3/2022, which updates the list of jurisdictions participating in the exchange of country-by-country (CbC) reports for the 2021 reporting period.
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Ireland

Restriction on interest deduction: On 21 December 2021, President signed the 2021 Finance Bill into Finance Act 2021 including new interest limitation rules. These rules are intended to limit base erosion through the use of excessive interest deductions. The rules will take effect for accounting periods of companies beginning on or after 1 January 2022.
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Jordan

Transfer pricing information return: On 2 January 2022, the Jordan Income and Sales Tax Department (ISTD) has published new transfer pricing documentation forms (Arabic) in line with Regulation No. 40 of 7 June 2021. Taxpayers with related party transactions equal to JOD 500,000 or more in a 12-month period are required to submit a transfer pricing disclosure with the annual tax return.
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Nigeria

CbC reporting requirement-General rule: On 4 January 2022, the Federal Inland Revenue Service (FIRS) issued a new Public Notice to announce that the withdrawal of its Public Notice of 6 May 2021 which suspended local filing obligations contained in Regulation 4 of the Income Tax (CbC Reporting) Regulations, 2018 imposed on branches and subsidiaries of Multinational Enterprises (MNEs) operating in Nigeria.
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Peru

Restriction on interest deduction: On 30 December 2021, the Peruvian Tax Administration (SUNAT) has issued Supreme Decree 402-2021-EF in the Official Gazette clarifying the regulations for interest deduction limitation rules. From 1 January 2021, interest exceeding 30% of EBITDA in the previous year will not be deductible.
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Singapore

Information exchange-Multilateral: On 21 December 2021, Singapore published the Income Tax Order 2018 including the addition of a seventh schedule listing the jurisdictions with which the CbC report exchange is effective as of 1 December 2020, and the addition of an eighth schedule listing the jurisdictions with which the CbC report exchange is effective from 31 March 2021.
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Spain

Compliance with BEPS standards: According to OECD’s latest publication regarding the position of signatories’ countries on the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), MLI entered into force for Spain on 1 January 2022.
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Ukraine

Compliance with BEPS standards: On 29 December 2021, the Ukraine Ministry of Finance has announced that the government has approved amendments to the law ratifying the tax treaty related measures to prevent Base Erosion and Profit Shifting (MLI). BEPS MLI entered into force with respect to Ukraine on 1 December 2019.
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Algeria

Incentives on industry/manufacturing: On 30 December 2021, the Finance Ministry Officially published the 2022 Finance Law. Accordingly, qualifying manufacturing companies are granted a reduced corporate tax rate of 10% on profits reinvested in the acquisition of fixed assets related to the company’s operations or invested in the acquisition of shares or other securities representing at least 90% ownership of the capital another manufacturing, construction or service company if certain conditions are met.

Withholding tax rate on dividends: Under the Finance Act, a 5% withholding tax rate is introduced on the income of resident legal persons from the distribution of profits (dividends) that have been subject to corporate income tax or expressly exempted.
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Bulgaria

CFC rules: On 20 January 2022, the Bulgarian Parliament passed the draft law amending and supplementing the Corporate Income Tax Act (CITA). The draft law provides for the correction of the Bulgarian implementation of the ATAD-CFC rules which will be applied to all Bulgarian taxable persons that are subject to corporate income tax in the country and have CFCs regardless of their form of taxation subject to approval in the second and final reading.
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Colombia

Filing return: On 20 December 2021, the Colombian Ministry of Finance and Public Credit has issued Decree 1778 specifying the deadlines for filing and payment of the tax return (declaration) in 2022. Some of the key deadlines for companies depend on the last digits of the taxpayer’s tax number (NIT).
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Costa Rica

Main corporate tax rate: On 22 December 2021, the Costa Rican government and the Ministry of Finance posted Decree No. 43375-H updating the corporate income tax thresholds for the tax year 2022.
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Hong Kong

Submission of returns: On 14 January 2021, the Inland Revenue Department of Hong Kong decided to extend the due date for filing Income Tax Returns 2020/21 for loss events with accounting date code “M” from 31 January 2022 to 28 February 2022.

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India

Filing return: On 11 January 2022, the Central Board of Direct Taxes has extended the filing of income tax returns and various audit reports for the 2021-22 tax years. According to the CBDT press release, the due date of furnishing the Income Tax Return for the Assessment Year 2021-22, which was 31 October 2021 and 30 November 2021, has been further extended to 15 March 2022.
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Lithuania

Corporate tax rate-special: On December 7, 2021, the Lithuanian Parliament passed several important amendments to the Law on Corporate Income Tax of the Republic of Lithuania. Accordingly, from 1 Jul 2022, the additional corporation tax of 5% on profits of banks and cooperative banks over EUR 2 million will apply indefinitely. The additional tax is charged in addition to the corporate tax rate of 15%.
Incentive: The law also proposed changing the conditions for applying for a corporate tax exemption for a period of up to 20 years for companies undertaking large investment projects.
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Malaysia

Losses-Carry forward: On 31 December 2021, the Finance Law 2021 was published in the Official Gazette and extended the period for carrying forward unabsorbed business losses from 7 to 10 years. In addition, the period for carrying forward and using special reinvestment allowances has been extended by a further two years, starting in 2025.
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Nigeria

Taxation of capital gains tax: On 31 December 2021, the President signed the Finance Bill 2021 into Law at an event in the State House. The bill introduced a rate of 10% capital gains tax on gains on disposals of shares in a Nigerian company where the gross proceeds from such sales exceed ₦100million for 12 consecutive months.
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Peru

Filing return: On 30 December 2021, the Peruvian tax authorities (SUNAT) have issued Resolution No. 000195-2021/SUNAT in the official gazette regarding the deadlines for corporate tax (CIT) returns for 2021. The Resolution states that Virtual Form No. 710 (applicable for CIT return) is available from 3 January 2022.
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South Africa

Sanctions for non-compliance: On 18 January 2022, the South African Revenue Service (SARS) published updated interest tables. The South African Reserve Bank changed the “repo rate” on 27 January 2022. The table includes Interest rates on outstanding taxes and interest rates payable on certain refunds of tax on successful appeals and certainly delayed refunds, which is increased from 7.0% to 7.25% with effect from 1 March 2022.
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Spain

Incentives: On 29 December 2021, the Spanish budget bill for the fiscal year 2022 was published in the Spanish Official Gazette. The bill introduces a minimum corporate tax rate of 15% of the tax base for certain taxpayers from 2022. For start-ups that benefit from the reduced rate of 15%, this minimum rate will be reduced to 10%.
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UAE

Main corporate tax rate: On 31 January 2022, the United Arab Emirates (UAE) Ministry of Finance announced the introduction of a corporate tax rate. The new regime, which is set to be introduced from 1 June 2023, introduces standard statutory tax rate of 9% and a 0% tax rate for taxable profits up to AED 375,000 to support small businesses and startups.
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Ukraine

Interest on late payment: On 20 January 2022, the National Bank of Ukraine has decided to increase its key policy rate from 9% to 10% per annum with effect from 21 January 2022. The interest rate has a tax effect on the late tax payment interest and penalties which is equal to 120% of the National Bank rate and also increases in the penalty interest rate from 10.8% to 12% per annum.
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Armenia

Interest received: On 14 December 2021, the Armenian Central Bank has announced the decision to increase the key rate from 7.25% to 7.75% with effect from December 2021. The interest rate of the Central Bank is used for the purposes of calculating interest deduction.
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Cyprus

Residence rules- incorporation: On 21 December 2021, an amendment to the Income Tax Law was published in the Cyprus Government Gazette. Accordingly, a company incorporated or registered in Cyprus and the management and control of which is exercised outside Cyprus should be regarded as resident in Cyprus for tax purposes unless it is resident in another country for tax purposes.
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France

Incentives for industry/manufacturing: On 16 November 2021, the government has introduced some incentives for innovation in the Finance Bill 2022, which would have been enacted by the end of December 2021.
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Greece

Main corporate tax rate: On 17 December 2021, the Finance Ministry announced an overview of tax measures on the 2022 Budget. The corporate income tax rate is reduced from 24% to 22% for legal entities and legal entities on a permanent basis.
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Ireland Incentives-Industry/manufacturing: On 14 December 2021, the Revenue published an eBrief 226/21, which updates a manual to clarify certain aspects of the Research and Development (R&D) Tax Credit.
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Italy

CFC-rules: On 27 December 2021, the Italian Tax Authority published Circular No. 18/E, which provides guidance on the rules for controlled foreign companies (CFCs). The Circular contains clarifications on the subjective and objective requirements for the application of the CFC regime.
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Malaysia

Incentives for others: On 30 December 2021, the Ministry of Finance (MoF) announced that foreign source income derived by resident taxpayers will be exempt from tax from 1 January 2022 to 31 December 2026.
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Netherlands

Payment procedures: Recently, the Dutch Tax and Customs Administration grant temporary special payment extensions to entrepreneurs, to help them cope with the corona crisis. Taxpayers can apply for a special tax payment extension for most taxes. The extension will be valid until and including 31 January 2022.
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Nigeria

Taxation of capital gains: On 7 December 2021, the Nigerian government proposed a 5% capital gains tax rate on the gains from the disposal of shares in any Nigerian company when the gross proceeds from such sales in any 12 consecutive months exceed ₦500million.
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Russia

Interest on late payments: On 17 December 2021, the Russian Central Bank has announced the decision to increase the key rate from 5% to 8.5% with effect from 20 December 2021. The new rate applies from The CBR’s key interest rate is used for the purposes of calculating interest deduction and late payment interest on overdue taxes.
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Special tax rate: On 25 November 2021, the Ministry of Finance (MoF) submitted Bill No. 25126-8 to Parliament. The law provides for a corporate tax rate of 0% for cultural institutions established by municipalities. If accepted, the 0% rate will apply from January 2022.
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Thailand

Incentives for industry/manufacturing: The government of Thailand has declared that it will extend the period of certain tax incentives for businesses located in the special economic development zones (SEZs) for 3 additional years, covering the period from 1 January 2021 to 31 December 2023.
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Turkey

Withholding tax rates-Dividends: On 22 December 2021, the Turkish Revenue Administration has issued Presidential Decision No. 4936 in the Official Gazette reducing the withholding tax rate on corporate dividends distributions from 15% to 10%.
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UK

Interest on late payments: On 17 December 2021, the UK HMRC has announced the revision of late payment interest rates following the base rate increase to 0.25% by the Bank of England. The Bank of England Monetary Policy Committee voted on 16 December 2021 to increase the Bank of England base rate to 0.25% from 0.1%. HMRC interest rates are linked to the Bank of England base rate.
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Ukraine

Incentives on services: On 20 December 2021, the President of Ukraine has signed Law No. 1946-IX providing ‘Diia City’ resident IT companies special tax and legal regime from 2022. This will come into force at the end of January 2022.
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Interest on late payments: On 9 December 2021, the National Bank of Ukraine has decided to increase its key policy rate from 8.5% to 9% per annum with effect from 10 December 2021.
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Sanction for tax evasion: On 17 November 2021, Ukraine has published Law No. 1888-IX in the Official Gazette increasing thresholds of criminal liability for tax evasion. The changes are applicable from 25 November 2021.
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Australia

Special rules for hybrid instruments or entities: On 16 December 2021, the Australian Taxation Office (ATO) issued Practical Compliance Guideline 2021/5 on imported hybrid mismatch rule relating to a practical administrative approach to the imported hybrid mismatch provisions in subdivision 832-H of the Income Tax Assessment Act 1997.

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Cyprus

CbC reporting requirement-Deadlines: On 20 December 2021, the Cyprus Tax Department published an announcement informing that the deadline for submission for local CbCR reporting due to the secondary filing mechanism (including Equivalent reporting) for the year 2020 is the 31st of January 2022 instead of the 31st of December 2021.
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Finland

OECD Guidelines: On 17 December 2021, the Finnish Tax Administration issued Guidance No. VH/5755/00.01.00/2021, on the application of OECD transfer pricing guidelines to domestic transfer pricing rules, effective from 31 December 2022.
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Adjustments: On 9 December 2021, the Finnish Parliament has approved the amendment to the transfer pricing adjustment provision, (VML Section 31) of the Tax Procedure Act (VML). The amendment will take effect on 1 January 2022 and will apply to tax years beginning on or after 1 January 2022.
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France

Special rules for hybrid instruments or entities: On 15 December 2021, the Tax Authority published a guide, which covers the measures implemented in compliance with the EU Anti-Tax Avoidance Directive as amended (ATAD1 and ATAD2) as part of the Finance Law for 2020. The hybrid mismatch measures generally applies from 1 January 2020, but the anti-hybrid mismatch rules will apply from 1 January 2022.
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Iceland

CbC reporting requirement-Deadlines: On 22 December 2021, Iceland published the Notice No.1490/2021 which provides that the CbC report notification in respect of the 2021 fiscal year is to be submitted by 31 January 2022.
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India

Safe harbor-Simplified arm’s length range: On 29 October 2021, the Central Board of Direct Taxes (CBDT) has published Notification No. 124/2021, which provides for a tolerance limit of 1% for wholesalers and 3% in all other cases for the arm’s-length pricing determination in the assessment year 2021 -22.
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Ireland

CbC reporting requirement-General rule: On 20 December 2021, the Department of Enterprise, Trade and Employment is seeking the views of stakeholders through a Consultation on the transposition of the new EU directive requiring public country-by-country (CbC) reporting of income tax information by certain large multinationals. The deadline for submissions of public consultation is 18 February 2022.
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Italy

Documentation-Requirement: On 26 November 2021, the Italian Tax Authorities issued Circular No. 15 providing clarifications on the regulations introduced on 23 November 2020 regarding the content and validity of the elective transfer pricing (TP) documentation available to Italian resident enterprises and Italian permanent establishments (PEs) of foreign entities to provide administrative penalty protection in the case of a TP assessment.
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Malta

Scope of transfer pricing rules: On 22 December 2021, Malta’s Commissioner for Revenue (CFR) has published draft Transfer Pricing Rules on its website for public consultation. The consultation period will end on 28 February 2022, and the draft Transfer Pricing Rules shall come into force with effect for financial years commencing on or after 1 January 2024.
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Panama

Penalties for documentation failure: On 11 November 2021, Panama published Law No. 254 in the Official Gazette No. 29413-A, which amends the legislation on international tax transparency and the prevention of money laundering, and the financing of terrorism. The amendment includes a penalty of PAB 100,000 plus PAB 5,000 per day of non-compliance for failing to comply CbC reporting requirements.
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Poland

Safe harbor-Simplified interest rates: On 24 December 2021, the Polish Official Gazette published a Regulation No. 1192, establishing base interest rates and margin rates for the purposes of transfer pricing for individual and corporate income taxes. The “Safe Harbor” interest rate applies when loans are concluded between related parties.
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Portugal

Documentation requirements: On 26 November 2021, the Portuguese Tax Administration (PTA) published Order No. 268/2021, which replaces Regulation No. 1446-C / 2001 of December 21, 2001. The ordinance changes the transfer pricing documentation rules by adding two new distinct documentation models the standard (composed of a master file and a local file) and the simplified (for small or medium-sized enterprises).
Documentation threshold: According to new order, taxpayers are exempt from the documentation requirements if, in the period to which the obligation relates, total annual income is less than EUR 10 million. Even if this limit is exceeded, that exemption shall apply to controlled transactions whose value in the period has not exceeded €100,000 and, in total, €500,000, considering their market value.
Documentation deadline: The taxpayers required to prepare the standard or the simplified model within the deadline for filing the Annual Accounting and Tax Information return (IES/DA) by the 15th day of the seventh month after the end of the financial year or on 15 July, if that Fiscal year coincides with the calendar year and can only be presented to the PTA upon request.
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South Africa

APAs-General rules: On 10 December 2021, the South African Revenue Service (SARS) made an announcement for inviting public comments for a model and draft legislation regarding Advance Pricing Agreement (APA) system until the end of January 2022.
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Spain

MAP: On 19 November 2021, the tax authorities have issued a guide and questions and answers (Q&As) on mutual agreement procedures (MAPs) to provide taxpayers with guidance on the main aspects of MAP.
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Thailand

CbC reporting requirement-Deadlines: On 23 December 2021, the Thai Revenue Department has published a notification on amendments to the filing deadlines for Country-by-Country (CbC) reports. Accordingly, the CbC reporting deadline has been amended to 12 months after the close of the relevant accounting period.
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US and Turkey

Information exchange-Bilateral: On 24 November 2021, US and Turkey have signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. A CbC report is intended to be first exchanged with respect to Fiscal Years of MNE Groups commencing on or after 1 January 2019.
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Zambia

CbC reporting requirement-General rule: On 29 October 2021, the Zambian government has presented the budget for 2022 to the Parliament. The budget introduces two new schedules that allow taxpayers to provide the information required by international country-by-country reporting (CbC) obligations, and it adds tax measures to encourage investment in special economic zones and the mining sector.
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