Transfer Pricing Brief: June 2023
Bolivia Filing deadlines: On 28 April 2023, the Bolivian National Tax Service published a Resolution No. 102300000014 extending the corporate income tax (IUE) reporting deadline for the tax year ending 31 December 2022 to 31 May 2023. See
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Nigeria: FIRS releases new guidelines on mutual agreement procedures
On 23 May 2023, the Federal Inland Revenue Service (FIRS) of Nigeria has released Information Circular No. 2023/04 which includes new Guidelines on Mutual Agreement Procedure (MAP). The purpose of the guidelines is to provide guidance on how to
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Kuwait: IMF Report Recommends Implementation of VAT and Excise Taxes
On 5 June 2023 the IMF published a report following consultations with Kuwait under Article IV of the IMF’s articles of agreement. Kuwait’s economy has begun to recover after the pandemic with economic growth estimated at 8.2% in 2022 as a
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Malaysia: IRBM gazettes APA Rules 2023
On 29 May 2023, the Malaysian Inland Revenue Board of Revenue (IRBM) published the Income Tax (Advance Pricing Arrangement) Rules 2023 ("APA Rules 2023") in their gazette with the following key changes. Taxpayers engaged in cross-border
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Denmark implements temporary solidarity contribution on fossil fuel sector
Denmark has released Law No. 502 dated 16 May 2023 in the Official Gazette, which establishes the implementation of a temporary solidarity contribution targeting the fossil fuel sector, aligning with Council Regulation (EU) 2022/1854. The measure
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Bangladesh: Budget for FY 2023-24
On 1 June 2023, the Finance Minister, Mr. AHM Mustafa Kamal presented the budget in parliament for the fiscal year 2023-24, aiming to accelerate economic growth, promote social development, and address key challenges faced by the nation. The budget
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Malaysia: IRBM publishes transfer pricing rules 2023
On 29 May 2023, the Malaysian Inland Revenue Board of Revenue (IRBM) officially published Order No P.U. (A) 165 (TP Rules 2023) introducing a new transfer pricing documentation process effective from assessment year 2023 onwards. The main changes
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Nigeria: Tax measures in Finance Act 2023
On 28 May 2023, the immediate past President, Muhammadu Buhari signed the Finance Bill-2023 into law as Finance Act, 2023("the Act"). The act includes the following tax measures related to corporate taxation: "Digital assets" have been
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Netherlands introduces draft legislation to implement BEPS Pillar Two rule
On 31 May 2023, the Dutch Government submitted a draft legislation to the Parliament in order to incorporate the BEPS 2.0 – Pillar Two requirements into its domestic laws. This draft legislation follows the previously released draft proposal of 24
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Spain releases a law introducing new interest deduction limitation rules
On 25 May 2023, Spain published Law 13/2023 in the Official Gazette, which introduces new interest deduction limitation rules in line with the EU Anti-Tax Avoidance Directive (ATAD). Spain's current rules limiting interest deduction were deemed
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France announces green industry bill with 15 key measures to secure European leadership
On 16 May 2023, as part of France's ambitions to become a leading green industry force in Europe, Finance Minister Bruno Le Maire unveiled the "Green Industry Bill." This comprehensive legislation includes a range of measures designed to propel
See MoreSpain approves corporate income tax return form for tax year 2022
On 22 May 2023, Spain published an “Order HFP/523/2023 of 22 May 2023” in the Official Gazette, approving the forms and instructions for the corporate tax and Non-Resident Income Tax returns for periods starting between 1 January and 31 December
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Portugal extends corporate tax filing deadline to 6 June 2023
On 22 May 2023, the Portugal's Secretary of State for Fiscal Affairs has issued Order No. 148/2023-XXIII. This order grants a brief extension for the submission of the annual corporate tax return and payment for the year 2022. Taxpayers now have
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Greece introduces new process for fossil fuel companies on temporary solidarity contribution return
On 8 June 2023, the Greek Public Revenue Authority (AADE) has recently issued Decision A. 1069, outlined the necessary procedures and return form for the temporary solidarity contribution imposed on fossil fuel companies. This move aligns with
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Saudi Arabia: ZATC issues a Circular on the taxation of PE in the context of DTA
On 17 May 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued Circular No. 2303001 regarding the taxation of Permanent Establishments (PEs) in the context of Double Taxation Agreements (DTA). The Circular serves to provide
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UAE clarifies interest deduction rules
On 23 May 2023, the United Arab Emirates (UAE) Ministry of Finance (MoF) published Decision No. 126 of 2023 on the general rules for limiting the deduction of interest for corporate tax purposes. To determine the deductible interest from taxable
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Vietnam deposits BEPS MLI ratification instrument
On 23 May 2023, Vietnam has deposited its instrument of approval for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention). This move makes Vietnam the 81st jurisdiction to
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Albania implements comprehensive income tax reform: major changes to corporate, individual, and withholding tax laws
On 2 May 2023, Law No. 29/2023 "On income tax" was published in Albania's official gazette, introducing significant changes to corporate income tax, individual income tax, and withholding tax. The new law will come into effect on 1 January 2024,
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