Algeria Transfer pricing information return: Algeria published the Supplementary Finance Law for 2023 in the Official Gazette. A new transfer pricing declaration obligation has been introduced, requiring taxpayers to submit an online transfer pricing declaration annually as per the model specified by the tax authority.
See the story in Regfollower
Costa Rica Main corporate income tax rate: On 7 December 2023, the Ministry of Finance of Costa Rica published Executive Decree No. 44276-H in the Official Gazette, outlining the corporate and individual income tax brackets and rates for 2024.
See the story in Regfollower
Ecuador Compliance: The Ecuadorian Tax Authority released a new edition of the technical sheet for the standardization of transfer pricing analysis, effective for fiscal year 2023. This updated document introduces significant changes to filing procedures, reporting requirements, and comparability analysis for transfer pricing purposes.
See the story in Regfollower
Ireland Documentation-Requirement: On 18 December 2023, the Irish Revenue issued eBrief No. 261/23 providing a new Tax and Duty Manual Part 35a-01-05 – Requests for Transfer Pricing (TP) Documentation.
See the story in Regfollower
Kazakhstan Scope of transfer pricing rules: Kazakhstan is undergoing a pivotal transformation in its transfer pricing framework, marked by the Majilis’ approval of substantial amendments to the existing legislation.
See the story in Regfollower
Latvia Digital economy transactions-General: Latvia issued the Law of 6 December 2023 on Amendments to the Law on Taxes and Fees (Duties), concerning the exchange of income information generated by sellers through digital platforms (DAC7). DAC7 mandates digital platforms to collect, verify, and report information on sellers who utilize their digital platforms to sell and provide defined products or services.
See the story in Regfollower
Netherlands CbC reporting requirement-General rule: The Dutch Senate (upper house of parliament) has passed the bill for implementing public Country-by-Country (CbC) reporting as required by Directive (EU) 2021/2101.
See the story in Regfollower
Papua New Guinea Compliance with BEPS standards: On 1 December 2023, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Papua New Guinea.
See the story in Regfollower
Russia Secondary adjustment: On 27 November 2023, Russia issued Law No. 539-FZ in the Official Gazette, which outlines several amendments to the country’s transfer pricing regime. The introduces secondary transfer pricing adjustments.
APAs-General rules: Law No. 539-FZ of 27 November 2023 has brought about changes concerning Advance Pricing Agreements (APAs). As per the modifications, APAs can now be established not only by major taxpayers, as was previously permitted, but also by taxpayers engaged in a controlled transaction meeting specific criterion.
APAs-Application procedure: Law No. 539-FZ of 27 November 2023 has modified the application period for Advance Pricing Agreements (APAs).
Penalties for documentation failure: The Law No. 539-FZ of 27 November 2023 has increased the penalties for transfer pricing violations.
See the story in Regfollower
Thailand APAs-General rules: Thai Revenue Department (TRD) published updated guidance on advance pricing arrangements (APAs). The update in the guidance mostly related to the information required to be included in the APA application.
See the story in Regfollower