Transfer Pricing Brief: February 2023
Argentina Scope of transfer pricing rules: On 27 December 2022, Argentina’s federal tax authority (AFIP) released General Resolution No.5306/2022, establishing a new mandatory disclosure regime for certain international transactions. The
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Tax Treaty News: January 2023
Austria and United Arab Emirates On 1 March 2023, the amending protocol to the Double Taxation Agreement (DTA) between Austria and the United Arab Emirates (UAE) will enter into force. The protocol generally applies from 1 January
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World Tax Brief: January 2023
Armenia Incentives-Industry/manufacturing: The Armenian parliament has approved a law for the extension of tax incentives for start-ups of information technology (IT) industry. The incentives include a 100% corporate income tax exemption and
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Tax Treaty News: December 2022
Chile and Netherlands On 30 November 2022, the Double Taxation Agreement (DTA) between Chile and Netherlands entered into force. The DTA contains withholding tax rates for Dividends 5% for at least 25% capital holding; otherwise, 15%,
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World Tax Brief: December 2022
Albania Treatment of losses-Carry forward: On 27 October 2022, the Albanian parliament is taking into account a draft bill, which proposed an amendment to the income tax law. The new bill extends the time period for loss carryover from 3
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Transfer Pricing Brief: December 2022
Argentina Compliance with BEPS standards: On 8 November 2022, the Argentine Commission on Foreign Affairs accepted a bill to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). See the story in
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Tax Treaty News: November 2022
Georgia and Poland On 27 October 2022, the Polish Senate approved the Double Taxation Agreement (DTA) with Georgia. Czech Republic and Qatar On 25 October 2022, the Double Taxation Agreement (DTA) between Czech Republic and Qatar
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World Tax Brief: November 2022
Belgium Submission of returns: On 30 September 2022, the Belgian Ruling Commission announced filing and prefiling requests related to the innovation income deduction and transfer pricing. According to the announcement, all prefiling requests
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Transfer Pricing Brief: November 2022
Azerbaijan Information exchange-Bilateral: On 26 October 2022, the President of the Republic of Azerbaijan published a law ratifying the Inclusive Framework on Base Erosion and Profit Shifting (BEPS), which was approved by the President on 11
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Tax Treaty News: October 2022
Georgia and Poland On 29 September 2022, the lower house of the Polish parliament approved the Double Taxation Agreement (DTA) with Georgia. Tanzania and UAE On 27 September 2022, the Double Taxation Agreement (DTA) between Tanzania and
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Transfer Pricing Brief: October 2022
Armenia Compliance with BEPS standards: On 14 September 2022, the Armenian Parliament (National Assembly) approved draft Bill No. K-294 for ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
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Tax Treaty News: September 2022
Kuwait and UAE On 30 August 2022, the Ministry of Finance of Kuwait declared the signing of a Double Taxation Agreement (DTA) with the United Arab Emirates (UAE). Czech Republic and Senegal On 29 August 2022, the Double Taxation
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Transfer Pricing Brief: September 2022
Australia Local file-General rule: On 9 August 2022, the Australian Taxation Office (ATO) updated guidance on the Local and Master file for 2022 along with instructions. The guidance applies to reporting periods beginning on or after 1
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Tax Treaty News: August 2022
Germany and Netherlands On 31 July 2022, the amending protocol to the Double Taxation Agreement (DTA) between Germany and Netherlands entered into force. The protocol will apply from 1 January 2023. Cambodia, Macau, and Turkey On 28
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World Tax Brief: August 2022
Argentina Advance payments due: On 28 June 2022, Argentine Official Gazette published General Resolution 5211/2022 amending the provisions on income tax advance payment. The resolution increases the thresholds for making advance payments
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Transfer Pricing Brief: August 2022
Cyprus Scope of transfer pricing rules: On 30 June 2022, the Cyprus House of Representatives enacted detailed transfer pricing legislation amending the Cyprus Income Tax Law (ITL) and the issuance of Regulations. The amendment includes the
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Ethiopia and Luxembourg On 22 June 2022, Luxembourg ratified the Double Taxation Agreement (DTA) with Ethiopia. Guernsey and Qatar On 21 June 2022, Qatar and Guernsey signed an amending protocol to update the Double Taxation Agreement
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Transfer Pricing Brief: July 2022
Dominican Republic CbC reporting requirement-Threshold: On 22 June 2022, the Directorate General of Internal Revenue (DGII) published a Notice (No. 18-22) clarifying CbC for Multinational Enterprises (MNEs). If the group reports and is
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