OECD: Consultation on Transfer Pricing Issues Relating to Lithium
On 6 November 2023 the OECD and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) released for public consultation a draft toolkit with the title Determining the Price of Minerals: Application to Lithium. The
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OECD: Guidance on Transfer Pricing Issues for Bauxite
Following the completion of a previous consultation, on 6 November 2023 the OECD published a toolkit with the title Determining the price of minerals: A Transfer Pricing Framework – Schedule A: Bauxite. This toolkit follows on from the publication
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OECD: Practice Note on Transfer Pricing for Minerals
On 6 November 2023 the OECD published the final version of a practice note with the title Determining the price of minerals: A Transfer Pricing Framework. The practice note has been developed after consultation with interested parties with the aim
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Philippines joins the inclusive framework to combat tax avoidance and implement BEPS standards
On 8 November 2023, the Philippines joined as a member of the Organisation for Economic Cooperation and Development (OECD)/G20 Inclusive Framework on Base-Erosion and Profit Shifting (BEPS) Inclusive Framework. The Inclusive Framework on BEPS is
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Australia increases interest rate for simplified transfer pricing record-keeping options for loans
On 8 November 2023, the Australian Taxation Office (ATO) released an updated version of practice compliance guideline on simplified transfer pricing record-keeping options (PCG 2017/2). The updates outline the safe harbor interest rate for the
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UAE: MoF declares new corporate tax decisions for free zones
On 3 November 2023, The UAE Ministry of Finance (MoF) released Cabinet Decision No. 100 of 2023, in which it outlines guidance for determining qualifying income and Ministerial Decision No. 265 of 2023 on qualifying activities and excluded
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Argentina announces tax Incentives to boost organic food production
On 12 October 2023, Argentina published Law 27734 in the Official Gazette, which outlined the establishment of a tax incentive regime to enhance organic food production. The incentives will be distributed to eligible producers and/or processors of
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Croatia announces amendments to profit tax law
On 4 October 2023, Croatia published the Amended Profit Tax Law in the Official Gazette with updated corporate tax rate threshold, withholding tax, tax return and so on. The main changes concerning corporate tax threshold and withholding tax
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Ireland: Revenue publishes registration guidelines for platform operators under DAC7
On 6 November 2023, the Irish Revenue issued eBrief No. 235/23, which provides registration Guidelines for platform operators for the exchange of information on income generated through digital platforms (DAC7). With effect from 1 January 2024,
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US: IRS introduces new measures to ensure tax payment by major corporations
On 20 October 2023, the US IRS announced new initiatives funded by the Inflation Reduction Act. These initiatives. These new initiatives aim to ensure that large corporations pay their outstanding taxes and intensify IRS efforts in pursuing
See MoreAustralia: ATO provides clarity on R&D tax incentive integrity rules
On 27 October 2023, the Australian Taxation Office (ATO) released a notice where it clarified the application of integrity rules for the R&D Tax Incentive. The identified issues with the application of some R&D program integrity rules
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Hungary approves new CbC exchange agreement with the US
On 2 November 2023, Hungary formally approved signing a new Country-by-Country (CbC) exchange agreement with the United States. The agreement—Decree No. 1482/2023—was published in the Official Gazette. This follows the previous CbC exchange
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Cyprus consents to the Pillar Two QDMTT and the transitional UTPR Safe Harbours
On 30 October 2023, the government of Cyprus released a press release announcing its consent to the design and application of the transitional Undertaxed Profits Rule (UTPR) Safe Harbour and the permanent Qualified Domestic Minimum Top-up Tax
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World Tax Brief: November 2023
Argentina Payment of tax: The Argentine Federal Tax Authority (AFIP) introduced General Resolution No. 5424/2023, requiring income tax prepayment for companies in Financial Intermediation, Insurance Services, or registered as payment service
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Lithuania: MoF publishes draft Law on implementation of Pillar 2 Global Minimum Tax
On 27 October 2023, the Lithuanian Ministry of Finance (MoF) published a draft law for the partial implementation of the Pillar 2 global minimum tax in accordance with EU Council Directive 2022/2523 of 14 December 2022. The proposed
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Albania introduces new income tax framework, bringing significant changes from 2024
On 20 September 2023, Albania released Income Tax Instruction No. 26 in the Official Gazette, laying the groundwork for the enforcement of Income Tax Law No. 29/2023. The Income Tax Law No. 8438/1998 was repealed and replaced by Law No. 29/2023,
See MoreHungary: MOF introduces draft legislation on BEPS 2.0 pillar two to parliament
On 31 October 2023, the Hungarian Ministry of Finance presented the draft legislation to the parliament regarding the implementation of EU Directive 2022/2523 on the global minimum tax. As previously reported, the Ministry of Finance released
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Saudi Arabia: ZATCA releases drafts of new income tax and tax procedural laws for public consultation
On 25 October 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued drafts of a new Income Tax Law and Zakat and Tax Procedures Law for public consultation. The public consultation period for comments on the drafts is open until 25
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