UK: Transfer Pricing and Diverted Profits Tax Statistics
On 7 February 2022 HMRC published the latest set of statistics relating to transfer pricing and the diverted profits tax. The latest release contains data up to end of the 2022/22 tax year. The transfer pricing work is an important part of
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Vietnam: MoF launches a public consultation regarding extension of tax payment deadlines
The Ministry of Finance (MoF) launches a public consultation on the proposed extension of tax payment time limit for corporate income tax, personal income tax and value added tax (VAT). The proposed extensions will apply as follows: The
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Malaysia: IRBM issues FAQs to clarify MAP guidelines
On 1 February 2023, the Inland Revenue Board of Malaysia (IRBM) has issued a list of frequently asked questions (FAQs) on the mutual agreement procedure (MAP) to provide further clarification to the 2017 MAP guidelines. In relation to the
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Jamaica: TAJ reminds tax filing deadline for the tax year 2022
On 2 February 2023, Tax Administration Jamaica (TAJ) reminded the taxpayers that the income tax filing deadline is 15 March 2023. The taxpayers are being reminded that filing their annual income tax return for the year 2022 and declaring their
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Turkey returns to general corporate income tax rate of 20% from 2023
In Turkey, the general corporate income tax rate of 20% is applicable from 1 January 2023. The rate was temporarily increased to 25% for 2021 and 23% for 2022. However, the tax rate is 25% for banks and financial sectors, 19% for companies doing
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Transfer Pricing Brief: February 2023
Argentina Scope of transfer pricing rules: On 27 December 2022, Argentina’s federal tax authority (AFIP) released General Resolution No.5306/2022, establishing a new mandatory disclosure regime for certain international transactions. The
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Singapore: Ministry of Finance Gazettes Order Declaring MCAA-CbC
On 27 January 2023, the Singaporean Official Gazette issued an Order No. S 26, which declares that the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country Reports (CbC) is an international tax compliance agreement
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Spain presents DAC7 bill to parliament
On 27 January 2023, Spain submitted a bill to Parliament for implementing Council Directive (EU) 2021/514 (DAC7), which requires digital platform operators to report the revenue generated by sellers on their digital platforms and for EU Member
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Ireland: Revenue updates guidance for charges on income for corporation tax purposes
On 1 February 2023, the Irish Revenue issued eBrief No. 025/23 regarding charges on income for corporation tax purposes. Accordingly, Tax and Duty Manual Part 08-02-01 has been updated. The updates include the following sections: In section
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South Africa: SARS updates interest rate tables
On 27 January 2023, the South African Revenue Service (SARS) has published updated interest rate tables . the interest rates tables are given below in three separate documents, numbered according to the following three categories: Table
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Hungary: MoF publishes decree amending TP rules on transfer pricing documentation
On 28 December 2022, the Hungarian Ministry of Finance published Decree 27/2022 (XII.28) which amends the Decree 32/2017 (X.18) on the documentation requirement related to the determination of arm’s length prices. Increase threshold
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Mozambique: Government approves proposal for corporate income tax cut
On 30 December 2022, the Law No. 20/2022 amending the corporate income tax code was published in the official gazette. Under the law, the Corporate Income Tax (IRPC) rate for agricultural, livestock, aquaculture and transport activities has been
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Italy publishes latest withholding tax return form
The Italian tax authorities have recently released the latest withholding tax return form for the fiscal year 2022. The withholding tax return form (Modello 770/2023) and instructions was approved by Protocol No. 25954/2023 on 27th January 2023.
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Russia updates the list of foreign states for automatic exchange of CbC reports
Recently, the Federal Tax Service of Russia published (Order No. ED-7-17/1226) a new list of foreign states and territories, with which Russia will automatically exchange Country-by-Country (CbC) reports. Accordingly, the following states are
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India: Finance Minister presents Union Budget for 2023-2024
On 1 February 2023, Ms. Nirmala Sitharaman, the Finance Minister of India presented the Union Budget for 2023-24 to the Parliament. The budget includes the following key tax proposals: Corporate tax proposals: A provision for tax treaty
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OECD: Technical Guidance for Implementation of the Global Minimum Tax
On 2 February 2023 the Inclusive Framework released technical guidance on implementation by governments of the global minimum tax. The Agreed Administrative Guidance for the Pillar Two GloBE Rules aims to ensure co-ordinated outcomes and greater tax
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OECD: Manual on Multilateral Mutual Agreement Procedures and APAs
On 1 February 2023 the OECD released the Manual on the Handling of Multilateral Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs) (the MoMA). Multilateral MAPs and APAs can offer greater tax certainty to both taxpayers
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OECD: Public comments received on the design elements of Amount B under Pillar One
On 30 January 2023 the OECD published the comments received on the design elements of Amount B under Pillar One relating to the simplification of transfer pricing rules. Comments were received from more than sixty businesses, institutes, NGOs and
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