OECD: Revised Methodology for the BEPS Action 14 Peer Reviews
On 24 January 2023 the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS) agreed a new assessment methodology for continuing the peer review process under BEPS action 14 to improve tax dispute resolution mechanisms. The
See MoreOECD: Revenue Impact of International Tax Reform
During a live webinar on 18 January 2023 the OECD presented the findings of a new analysis of the estimated impact on tax revenue of the implementation of the two-pillar international tax reform. The new analysis carried out by the OECD indicates
See MoreOECD: Tax certainty for Pillar Two rules
On 20 December 2022 the OECD issued a consultation document on providing tax certainty under the Pillar Two GloBE rules. Comments are invited from interested parties by 3 February 2023. The GloBE rules are to be enacted by each jurisdiction into
See MoreOECD: Peer Review Report on Dispute Resolution Mechanisms in Vietnam
The second stage peer review report on the implementation of the Action 14 minimum standard (making dispute resolution more effective) in Vietnam was published by the OECD’s Inclusive Framework on 13 September 2022. The report notes that
See MoreOECD: Peer Review Report on Dispute Resolution Mechanisms in Thailand
The second stage peer review report on the implementation of the Action 14 minimum standard (making dispute resolution mechanisms more effective) by Thailand was published by the OECD’s Inclusive Framework on 13 September 2022. The report notes
See MoreOECD: Peer Review Report on Dispute Resolution Mechanisms in the UAE
The second stage peer review report on the implementation of the Action 14 minimum standard (making dispute resolution mechanisms more effective) by the United Arab Emirates (UAE) was published by the OECD’s Inclusive Framework on 13 September
See MoreOECD: Peer Review Report on Dispute Resolution Mechanisms in Qatar
The second stage peer review report on the implementation of the Action 14 minimum standard (making dispute resolution mechanisms more effective) by Qatar was published by the OECD’s Inclusive Framework on 13 September 2022. The report notes
See MoreOECD: Peer Review Report on Dispute Resolution Mechanisms in Oman
The second stage peer review report on Oman’s implementation of the minimum standard under BEPS Action 14 (making dispute resolution mechanisms more effective) was published by the OECD’s Inclusive Framework on 13 September 2022. The report
See MoreAustralia: Consultation on Multinational Tax Integrity and Tax Transparency
A consultation launched by the Australian government on 5 August 2022 sets out measures that would help to address tax avoidance by multinational groups. Comments are invited by 2 September 2022. The package would implement part of the
See MoreOECD Tax Talk looks at international tax developments
The OECD Tax Talk held on 21 February 2022 provided an updated on important elements of tax work at the OECD. Two-Pillar International Tax Package Public consultations have begun and will cover the various building blocks of Pillar One on a
See MoreSwitzerland: Review of international financial and tax developments in 2021
On 25 January 2022 Switzerland’s State Secretariat for International Financial Matters published its summary for 2021 entitled: Swiss financial and tax centre in 2021: more sustainable, more digital and in good shape despite the pandemic. The
See MoreOECD releases latest edition of the Transfer Pricing Guidelines
On 20 January 2022 the OECD released the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The latest edition of the guidelines includes changes made to the 2017 edition by reports issued by
See MoreIndia: CBDT notifies the arm’s-length pricing variation limit for 2021-22
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
See MoreIreland: Revenue updates TP rules for some qualifying companies
On 6 September 2021, the Revenue updated its guidance to assist some qualifying companies in accordance with Section 110 regarding the application of transfer pricing (TP) rules and other issues. Under Section 110, a company be a qualifying one if
See MoreOECD: Updates to Transfer Pricing Country Profiles
On 3 August 2021 the OECD issued an updated version of some of its transfer pricing country profiles, These include new country profiles for Angola, Romania and Tunisia, and updated profiles for seventeen other countries. The updated profiles have
See MoreCanada: The Budget implementation Bill 2021 receives Royal Assent
On 29 June 2021, the 2021 Budget Implementation Act (“Bill C-30”) received Royal Assent, which includes certain tax measures that were proposed in the 2021 Federal Budget, the 2020 Fall Economic Statement, and the 2019 Federal Budget. Bill
See MoreBrazil: Executive Branch sends second phase of draft tax reform to Congress
On 25 June 2021, the Executive Branch sent the second stage of the tax reform proposal to Congress. This Tax reform includes the following changes: Government proposed to reduce the corporate income tax rate from 15% to 12.5% in 2022 and to 10%
See MoreUN: Third edition of the Practical Manual on Transfer Pricing for Developing Countries
Following approval at the twenty-second session of the UN Committee of Experts on International Cooperation in Tax Matters, held from 19 to 28 April 2021, the UN has published the third edition of its Practical Manual on Transfer Pricing for
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