Ireland publishes new guidance on requesting TP documentation
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. This Tax and Duty Manual documents the operational policy of the Transfer
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Italy releases draft tax returns and rules for 2024
On 22 December 2023, the Italian Revenue Agency published the draft tax return forms and instructions for filing in 2024. The tax return forms include the personal income tax return, the corporate tax return, the partnership tax return, the regional
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Germany updates tax haven defense ordinance: Adds and removes jurisdictions in response to EU decision
On 20 December 2023, Germany issued the Ordinance, amending the Tax Haven Defense Ordinance, as published in the Official Gazette. The Tax Haven Defense Ordinance plays a critical role in identifying jurisdictions considered non-cooperative under
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Germany: Bundesrat approves secondary credit market promotion Act
On 14 December 2023, upper house of parliament (Bundesrat) granted approval to the Secondary Credit Market Promotion Act. The Act had already received approval from the German Bundestag (lower house of parliament) on 13 December 2023 and is
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UAE: FDA issues guidance on corporate tax for natural personsÂ
On 24 December 2023, the UAE Federal Tax Authority (FTA) issued a release about publishing a guide outlining criteria for determining natural persons subject to Corporate Tax and their compliance requirements. The law came into effect on 1 June
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Armenia: Central bank lowers refinancing interest rate
On 12 December 2023, the Armenian Central Bank announced that it lowered the refinancing interest rate from 9.5% to 9.25%. This is the fifth interest rate reduction for 2023. The previously reduced refinancing interest rates are as follows:
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UN Resolution Paves Way for Equitable Global Tax Framework
The UN's Resolution A/C.2/78/L.18/Rev.1, proposed by Nigeria, represents a critical stride in establishing a UN Framework Convention on International Tax Cooperation. It confronts longstanding disparities born from decades of OECD-dominated tax
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Peru updates tax code on interest for refunds and penalties
On 20 December 2023, Peru’s Congress announced it amended its tax code concerning Law 31962. The amendment is related to the interest rate that the Tax Authority should consider involving cases on refund claims for improper or excessive tax
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Ireland passes finance act (no. 2) 2023 for 2024 budget and pillar 2 global minimum taxÂ
On 18 December 2023, Ireland enacted the Finance Act (No. 2) 2023 (Act No. 39 of 2023), which contains provisions for the Pillar 2 global minimum tax in line with Council Directive (EU) 2022/2523 of 14 December 2022. In addition to the Pillar 2
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Ukraine provides clarification on windfall tax for banks
On 23 December 2023, the State Tax Service of Ukraine released Newsletter No. 6/2023, which provides clarification on the implementation of the windfall tax on banks per Law 3474-IX. This legislation introduced a tax rate of 50% on bank profits for
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Croatia approves pillar 2 global minimum tax
On 22 December 2023, Croatia announced in the Official Gazette that it approved the Law on Minimum Global Profit Tax. The Croatian Parliament adopted the legislation on 15 December 2023. This law enacts the implementation of the Pillar 2 global
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Switzerland to implement pillar 2 global minimum tax in 2024
On 22 December 2023, the Swiss Federal Council published a release in which it confirmed enforcing the Pillar 2 global minimum tax in Switzerland from 1 January 2024. As previously reported, the Federal Council will gradually introduce the global
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Belgium enacts law on public CbC reporting
On 21 December 2023, the Belgian Chamber of Representatives passed a legislation for enacting the public Country-by-Country (CbC) reporting as required by Directive (EU) 2021/2101. The Directive mandates that a company is subject to public
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Canada mulls tax credits for clean hydrogen and tech manufacturingÂ
On 20 December 2023, Canada's Department of Finance launched consultations on introducing tax credits for clean hydrogen investment and Clean Technology Manufacturing investment. As detailed in the 2023 Fall Economic Statement, the government is
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Brazil passes major indirect tax reformsÂ
On 20 December 2023, Brazil passed Constitutional Amendment No. 132 of 20 December 2023, introducing major indirect tax reforms. These reforms will replace or unify several existing indirect taxes with new tax measures. The taxes that are
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Czech Republic: President approves law to enact global minimum tax
On 14 December 2023, according to an update released by the Czech Republic Parliament, President Petr Pavel signed the law to implement the Pillar 2 global minimum tax under the Council Directive (EU) 2022/2523 of 14 December 2022. On 29 December
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Argentina issuing bonds for state reconstruction
On 22 December 2023, the Argentine government issued Decree No. 72/2023 concerning the Bonds for the Reconstruction for a Free Argentina or Bonos para la Reconstruccion de una Argentina Libre (BOPREAL). The Argentine Central Bank will issue BOPREAL
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Colombia announces new TP documentation deadlines for 2023 and later
On 22 December 2023, Columbia released Decree 2229, introducing revised deadlines for submitting various forms of transfer pricing documentation. These include the informative declaration, country-by-country (CbC) notification, Local file, Master
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