OECD: Comments Received on Proposed Guidance on Pricing of Lithium
On 26 February 2024 the OECD published the responses received on the proposed guidance to support developing countries in addressing risks of base erosion and profit shifting in pricing lithium. Comments were received from eleven government and
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Germany: MoF issues updated guidelines on permanent establishment criteria and remote work
On 5 February 2024, the German Ministry of Finance (MoF) issued revised instructions concerning the criteria for a permanent establishment (PE), as commonly outlined in section 12 of the General Tax Code for the purposes of domestic tax law.
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Singapore: IRAS updates list of jurisdictions under CbC reporting
On 23 February 2024, the Inland Revenue Authority of Singapore (IRAS) revised its Country-by-Country Reporting (CbC) guidance page regarding the jurisdictions eligible for automatic exchange of CbC reports. Papua New Guinea has been included in the
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Nigeria: FIRS shifts e-platform for transfer pricing and CbC reporting notifications
Nigeria’s Federal Inland Revenue Service (FIRS), in a notice to taxpayers and the general public, announced the transitioning of the electronic platform for filing transfer pricing returns and country-by-country (CbC) reporting notifications from
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Malta to partly enact pillar 2 global minimum taxÂ
On 20 February 2024, Malta published Legal Notice No. 32 of 2024 in the Official Gazette, which outlines the provisions of the global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the European Union
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US: IRS announces tax relief for California taxpayers impacted by storms and floods
On 27 February 2024, the US Internal Revenue Service (IRS) announced that it is providing tax relief for individuals and businesses in parts of California affected by severe storms and flooding that began on 21 January 2024. According to the IRS
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Malaysia issues guidelines for service tax changes for 2024
On 26 February 2024, the Royal Malaysian Customs Department released the Service Tax (Rate of Tax) (Amendment) Order 2024, which was first published in the Official Gazette. This order implements the changes to the service tax, which goes into force
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Egypt raises materiality threshold for master file and local file for 2024
On 15 February 2024, Egypt published the Ministerial Decree No. 52 of 2024 in the Official Gazette, providing updated transfer pricing documentation requirements for Egyptian taxpayers. This decree came into effect on 22 February 2024. In this
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Cyprus extends deadline for 2022 transfer pricing documentation submissionÂ
On 23 February 2024, the Cyprus Tax Department (CTD) issued a letter that clarified the extension of the deadline for submission of the income tax returns of companies obligated to submit the Table of Summarised Information (TSI) for 2022. The
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Greece proposes new law to implement EU minimum tax rules
On 23 February, 2024, the Greek Ministry of Finance initiated a public consultation on a proposed bill aiming to incorporate the OECD’s Pillar Two Model Rules, as outlined in the EU Minimum Tax Directive. This draft bill is currently open for
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Switzerland releases Q&A guidance on application of transfer pricing rules
On February 23, 2024, the Swiss Federal Tax Authorities (SFTA) published the Q&A guidance regarding the application of transfer pricing regulations in Switzerland. This guidance clarifies the application of the arm's-length principle and the
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Albania: New law brings significant changes to withholding tax applicationÂ
Albania’s newly enacted Income Tax Law No. 29/2023 significantly modifies the imposition of withholding tax. One key aspect of this updated income tax legislation is the distinction it highlights between payments to registered persons (local
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Ukraine reports 2023 transfer pricing adjustments results and penalty relief
On 22 February 2024, the State Tax Service of Ukraine published a release about the outcome of the transfer pricing adjustments in 2023. The release mentioned that from 1 August 2023 until the conclusion of martial law in Ukraine, taxpayers can
See MoreUS: IRS announces unchanged interest rates for overpaid and underpaid tax for 2024
On 21 February 2024, the US Internal Revenue Service (IRS) declared the interest rates for overpayments and underpayments. As per the announcement, the interest rates will remain the same for the calendar quarter beginning 1 April 2024. For
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Belgium: Parliament approves law for mandatory e-invoicing in 2026Â
On 20 February 2024, the Belgian parliament passed the Law of 6 February 2024, which was published in the Official Gazette. The legislation amends the Value Added Tax Code and the Income Tax Code, making electronic invoicing compulsory from 1
See MoreUN: Committee Discusses Terms of Reference for Framework Convention on Tax
On 20 February 2024 the first meeting took place of the Ad Hoc Committee to draft terms of reference for a UN Framework Convention on International Tax Cooperation. The Committee was established by UN Resolution 78/230 of 22 December 2023. It aims
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OECD: Report on the Simplified and Streamlined Approach Under Amount B
On 19 February 2024 the OECD/G20 Inclusive Framework released the report on Amount B of Pillar One, following a previous consultation. The report sets out how jurisdictions can choose to apply the simplified and streamlined approach to qualifying
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Portugal: Central administrative Court upholds deductions for payments to low-tax jurisdictions
On 11 January 2024, the Central Administrative Court of the Southern Region in Portugal made a decision regarding the deductibility of payments made to jurisdictions with low tax rates. The case involved a major company providing aircraft
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