The Ministry of Finance published a draft amendment to the Tax Ordinance and other laws on Friday. The document includes significant changes regarding the reporting of tax schemes (MDR). The key points from the draft are:
- Elimination of the possibility to obtain an individual tax ruling on tax schemes;
- Elimination of the supporting entity function – only one entity will remain, the promoter, which will combine both functions;
- Modification of the definition of a hallmark and the main benefit;
- Removal of the reporting obligation if the information has already been provided in transfer pricing documentation or in reports on payments to non-residents subject to WHT;
- Removal of the obligation for certain entities to have an MDR procedure in place;
- Standardization of the MDR-3 submission deadline, with penalties for late submission;
- Introduction of the possibility for an attorney to sign MDR-3 on behalf of the taxpayer;
- Authorization for the Minister of Finance to grant exemptions from the reporting obligation for certain types of domestic arrangements and specific groups of entities.
In our next post, we will provide an in-depth analysis of these changes. Should you have any questions, feel free to contact us.
