Israel introduces three-tiered TP documentation requirements
On 30 June 2022, the Israeli Parliament passed legislation to amend Section 85A of the Income Tax Ordinance (ITO) and its regulations, by introducing three-tiered transfer pricing documentation requirements of BEPS Action 13. The legislation
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UK: Research into Value of Low-Risk Status to Businesses
On 19 July 2022 HMRC published the results of research conducted into the value of Low-Risk status to large businesses. The results of the research were used as an input into the design of the new Business Risk Review (BRR+) process that was
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UK: Large Business Customer Survey for 2020
On 19 July 2022 HMRC published the results of the Large Business Customer Survey for 2020. HMRC commissions the Large Business Customer Survey, conducted each year since 2015, to help assess the attitudes of business to their interaction with
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Germany enacts the bill on the interest rate for late payment
On 21 July 2022, The Ministry of Finance published the bill providing for a reduced rate for late interest payments on excess payments and refunds of tax in the Official Gazette. The bill had been previously approved by the lower house of the
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Philippines issues MAP Guidelines
The Philippines Bureau of Internal Revenue (BIR) has published Revenue Regulations No. 10/2022 on mutual agreement procedure (MAP) guidelines and process for requesting MAP assistance. The MAP article in the Double Taxation Agreements or tax
See MoreKazakhstan issues Law on amendments to the tax code
On 11 July 2022, Kazakhstan issued Law No. 135-VII on amendments to the tax code which will be effective from 1 January 2023. The Tax Code of the Republic of Kazakhstan provides for a number of following changes: Limitation of deductions
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OECD: Summary of progress on Amount A of Pillar One
On 11 July 2022 the OECD published for consultation a Progress Report on Amount A of Pillar One. Further input is invited from commentators by 19 August 2022 in relation to the technical design of Amount A. Following the Statement on the
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Australia revises guidance on diverted profits tax
On 13 July 2022, the Australian Taxation Office (ATO) issued updated guidance on the application of Diverted profits tax. The diverted profits tax (DPT) achieves the following outcomes: Aims to ensure that the tax paid by significant global
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Australia issues guidance on changing in loss carry back choice
The Australian Taxation Office (ATO) has published guidance on how to change a loss carry back choice and whether a change will affect assessments for subsequent income years. Changing loss carry back choice When taxpayers made original loss
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Sri Lanka declares penalty relief measure
On 1 July 2022, Sri Lankan Inland Revenue Department (IRD) has published a notice on penalty relief for the payment of taxes due up to financial year 31 December 2021. The summary of notice is following: The penalty relief measure is
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Thailand: BEPS MLI in Force
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Thailand on 1 July 2022. With regard to the double taxation agreements between Thailand and other
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Netherlands publishes new transfer pricing decree
On 1 July 2022, the Netherlands Ministry of Finance issued Decree No. 2022-0000139020 related to the application of the arm's length principle and the OECD transfer pricing guidelines. The New Decree replaces the previous transfer pricing (TP)
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Nigeria: FIRS extends tax return filing due date for companies
On 4 July 2022, the Federal Inland Revenue Service (FIRS) of Nigeria has announced to extend the submission of company income tax return for the 2022 year of assessment. Accordingly, the filing of Companies Income Tax Returns for the 2022 Year of
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Kenya: Major changes in transfer pricing rules under Finance Act 2022
On 8 July 2022, the Kenyan Finance Act 2022 was gazetted which was signed into law by the President on 21 June 2022. The law introduced a number of changes to the transfer pricing regulatory framework in Kenya that will have far-reaching
See MoreParaguay extends deadlines of TP returns
On 23 June 2022, the tax authority has extended the deadlines to submit the transfer pricing (TP) informative returns related to commodities exports through General Resolution 116. The Resolution came into force on 24 June 2022. The deadlines are
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IMF Report Looks at the US Economic Situation
On 12 July 2022 the IMF published a report following consultations with the US under Article IV of the IMF’s articles of agreement. The US has recovered quickly from the economic shock caused by the pandemic although the recovery of demand,
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Saudi Arabia issues draft Transfer Pricing Bylaws for public consultation
On 4 July 2022, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued a draft of Transfer Pricing (TP) Bylaws and invited public consultation. The public consultation period is open until 30 July 2022. The final Transfer Pricing Bylaws
See MoreGreece publishes lists of Jurisdictions for Automatic Exchange of Information on CbC reporting
Recently, the Ministry of Finance published a decision containing the list of jurisdictions to which it will apply the OECD Agreement on the Automatic Exchange of Information on Country-by-Country Reporting (CbC) (2016) in 2022 concerning the
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