US and Germany sign CAA regarding CbC exchange arrangement
On 24 March 2023, US and Germany signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. The Competent Authorities desire to conclude this Arrangement on the exchange of CbC Reports based on domestic reporting and
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Kuwait: Ministry of Finance introduces sampling basis tax inspection process
On 2 April 223, the Kuwait Ministry of Finance published Ministerial Resolution No. 24 of 2023 in the Official Gazette introducing a new tax inspection process. At present, the Ministry of Finance has subjected each tax declaration filed by a
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Transfer Pricing Brief: April 2023
Australia Restriction on interest deduction: On 16 March 2023, the Australian Treasury issued the Exposure Draft on the earnings before interest, taxes, depreciation, and amortization interest limitation rules (EBITDA). Consultation closes on
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Hong Kong: IRD issues profits tax, property tax and employer’s returns for 2022-23
On 3 April 2023, the Inland Revenue Department issued about 220 000 profits tax returns, 120 000 property tax returns and 310 000 employer's returns for the year of assessment 2022-23. About 2.4 million of tax returns for individuals will be issued
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Costa Rica extends filing deadline for inactive entities
On 29 March 2023, Costa Rica issued Resolution No. MH-DGT-RES-007-2023 providing an extension of filing annual informative return for inactive entities. Usually, inactive entities are required to file their informative return by 30 April of each
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Serbia: MoF adopts arm’s length interest rates for 2023
On 29 March 2023, the Serbian Ministry of Finance has approved the rulebook on arm’s length interest rates for 2023. The rulebook will be effective from 6 April 2023. Interest rates in accordance with “arm’s-length” principle that applies
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Japan enacts tax reform bill to align with OECD BEPS 2.0 Pillar Two
On 28 March 2023, Japan enacted its tax reform bill 2023 shortly after it passed in the Japanese Diet. The bill incorporated laws to implement the international tax reform in alignment with the OECD BEPS 2.0 Pillar Two initiative, based on the model
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India: CBDT extends time of Compulsory e-Filing of WHT Form 10F
On 28 March 2023, the Directorate of Income Tax declared that the relaxation granted for the e-filing of Form 10F for withholding tax by non-resident taxpayers who do not possess an Indian PAN number has been extended until September 30, 2023. In
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India: Finance bill 2023 passed in the lower house of Parliament
On 24 March 2023, the lower house of Parliament (Lok Sabha) passed the Finance Bill 2023 which implements tax proposals for the next fiscal year. The Bill received 64 official amendment proposals, among which one intends to remove extended tax
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UK enacts Mandatory Disclosure Rules
The OECD Model Mandatory Disclosure Rules (MDR), which require the disclosure of cross-border tax avoidance arrangements, enacted in the UK on 28 March 2023. The MDR imposes an obligation on taxpayers and advisers to provide information to the tax
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Finland: President signs the law on windfall taxes in electricity and fossil fuel companies
On 23 March 2023, Finnish President signed a law introducing temporary excess profit taxes on electricity and fossil fuel companies. The temporary taxes generally apply for the tax year 2023. Under the law, an additional 30 % profit tax will be
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Vietnam sign MAAC for implement Pillar Two global minimum tax
On 22 March 2023, Vietnam signed the Convention on Multilateral Administrative Assistance in Tax Matters (MAAC) to apply international cooperation for tax administration, prevent tax evasion and avoidance. With the inclusion of Vietnam, MAAC now
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Singapore: IRAS updates list of jurisdictions under CbC reporting
On 24 March 2023, the Inland Revenue Authority of Singapore (IRAS) updated the list of countries involved in the automatic exchange of Country-by-Country reports (CbC) under the Multilateral Competent Authority Agreement (MCAA). Israel is included
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Poland releases decree extending CIT return deadline
On 21 March 2023, the Polish Ministry of Finance published a decree extending the deadline for filing corporate income tax returns (CIT) and the related payment. According to the decree, the obligation to pay corporate income tax and to file the
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Indonesia announces tax incentives to encourage investment in Nusantara
Indonesia issued Government Regulation No. 12 of 2023 (GR 12/2023) to facilitate the process of doing business in the new capital and to encourage companies to invest in Nusantara. The regulation aims to provide more security, opportunity and
See MoreIMF Report Considers the Economic Outlook in Poland
On 24 March 2023 the IMF published a report following discussions with Poland under Article IV of the IMF’s articles of agreement. The report notes that the Polish economy has been facing difficulties as a result of the Ukraine war. Economic
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Chile launches public consultation on MAP
The Internal Revenue Service (SII) of Chile has launched a public consultation on a draft circular that aims to clarify the 3-year deadline for submitting a mutual agreement procedure (MAP) request. The SII is accepting feedback from the public
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Sweden proposes implementation of global minimum tax law
The Ministry of Finance has issued a memorandum containing suggestions and explanations to supplement the preliminary report on the implementation of the EU global minimum tax directive. On 7th February 2023, preliminary report was presented to the
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