Bosnia and Herzegovina implements advance tax ruling regulations
The Federal Ministry of Finance has implemented changes to the regulations governing advance tax rulings within the Federation of Bosnia and Herzegovina. Under the revised regulations, a standard template has been introduced for taxpayers seeking
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Germany issues new guidance on advance ruling procedures
The Ministry of Finance has issued new guidance on section 89a of the General Tax Code (GTC), which has been the legal basis for advance ruling procedures since 2021. Published on 26 June 2024, the guidance clarifies the application and
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Bangladesh: Government likely to announce tax rates for companies and individuals in advance
The Bangladeshi government is rumoured to be considering announcing income tax rates for individuals and companies in advance, ahead of FY25 budget, as part of a new system which will enable taxpayers to make informed investment and tax
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Bosnia and Herzegovina adopts new tax ruling regulations
The Ministry of Finance of the Federation of Bosnia and Herzegovina (FBiH) has adopted new regulations and procedures for advance tax rulings, effective from 1 June, 2024. These changes allow the Federal Tax Administration to issue various
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Malaysia: IRBM announces updated guidelines for advance pricing arrangement (APA)
The Inland Revenue Board of Malaysia (IRBM) has revised its Advance Pricing Arrangement (APA) guidelines to align with updates introduced in the Income Tax (Advance Pricing Arrangement) Rules 2023, introduced in May, 2023. The revision imposes
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OECD: Tax Administration 2022
On 23 June 2022 the OECD’s Forum on Tax Administration (FTA) issued Tax Administration 2022, which is the tenth edition of the report. The report sets out internationally comparative data on various features of tax systems and tax
See MoreOECD: Peer Review Report on Harmful Tax Practices
On 14 December 2021 the OECD published a report entitled: Harmful Tax Practices – 2020 Peer Review Reports on the Exchange of Information on Tax Rulings. The standard under Action 5 of the OECD/G20 action plan on base erosion and profit
See MorePortugal publishes new APA rules
On 26 November 2021, the Portuguese Tax Administration (PTA) was published Ministerial Order No. 267/2021 which revises the regulations on the procedures for concluding Advance Pricing Agreements (APAs) in accordance with Article 138 of the Code
See MoreIndia: CBDT notifies a formula to adjust MAT relief for secondary adjustment and APA
On 10 August 2021, the Central Board of Direct Taxes (CBDT) has published Notification No. 92/2021, which contains a new rule for calculating tax relief in the event of an increase in book profit as a result of adjustments to Advance Pricing
See MoreOECD: Peer review reports under BEPS Action 14
On 15 April 2021 the OECD released peer review assessments under Action 14 of the project on base erosion and profit shifting (BEPS) which aims to make dispute resolution mechanisms more effective. These stage two monitoring reports relate to
See MoreOECD: Transfer Pricing Implications of the Pandemic
On 18 December 2020 the OECD issued Guidance on the transfer pricing implications of the COVID-19 pandemic. This looks at the impact of the pandemic on areas of the transfer pricing analysis and APAs. Comparability analysis The pandemic and
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UK: Updated Statistics on Transfer Pricing and Diverted Profits Tax
On 12 November 2020 HMRC published updated statistics relating to transfer pricing and the diverted profits tax for 2019/20 (the year to 31 March 2020). In 2019/20 a total of 125 transfer pricing enquiries were settled, with an average
See MoreLuxembourg: Parliament approves budget law for 2020
On 19 December 2019, Luxembourg Parliament approved 2020 budget law which was presented by Luxembourg’s Finance Minister on 14 October 2019. According to the budget law, the advance tax rulings issued by the Luxembourg tax authorities before 1
See MoreLuxembourg: Finance Minister presents draft budget law for 2020
On 14 October 2019, Pierre Gramegna, Luxembourg's Finance Minister, presented draft budget law 2020 to the Parliament. According to this law, advance tax rulings issued before 1 January 2015 will be automatically invalid as from the end of the
See MoreDominican Republic: DGII updates transfer pricing brochure
On 7 February 2019, The Dominican Republic’s Directorate General of Internal Revenue (DGII) published online brochure to update guidance on transfer pricing. The brochure makes a number of following changes on transfer pricing: Reporting
See MoreIndia proposes changes in advance ruling forms for transparency in cross-border deals
On 10 April 2018, the central board of direct taxes (CBDT) issued a draft which includes changes to the income tax rules and forms to align them more closely with the OECD’s base erosion and profit shifting (BEPS) Action 5. The draft essentially
See MoreIndia: CBDT signed first bilateral APA with US
On 5 January 2018, the Indian Central Board of Direct Taxes (CBDT) signed the first bilateral advance pricing agreement (APA) with the United States. The CBDT has also indicated that there are many more bilateral APAs with the United States
See MoreIndia clarifies position on acceptance of the MAP and bilateral APA
On 27 November 2017, the Indian Government has announced that the MAP for transfer pricing disputes and the bilateral advance pricing agreement (APA) process would be available to taxpayers even where Article 9(2) or the equivalent is not present in
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