India: CBDT signs record number of 125 advance pricing agreements in FY 2023-24
The Central Board of Direct Taxes (CBDT) has accomplished a landmark achievement by finalizing a record 125 Advance Pricing Agreements (APAs) during the fiscal year 2023-24 with Indian taxpayers. This figure includes 86 Unilateral APAs (UAPAs) and
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Hungary releases 2024 audit plan with targets transfer pricing
Hungary's National Tax and Customs Administration (NAV) has released its audit strategy for the 2024 calendar year, highlighting transfer pricing as its key area of focus among other sectors. The new transfer pricing reporting obligation introduced
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Canada: CRA releases new circular on advance pricing arrangements (APAs)
On 22 February 2024, the Canada Revenue Agency (CRA) released the Information Circular 94-4R2 on International Transfer Pricing: Advance Pricing Arrangements (APAs). This circular offers detailed guidance on APAs, focusing on the prerequisites for
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UK: Transfer Pricing and Diverted Profits Tax Statistics
On 25 January 2024 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 2022/23 tax year. The transfer pricing work is an important part of
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Switzerland publishes transfer pricing guidelines
On 23 January 2024, the Swiss Federal Tax Administration published the updated Transfer Pricing Guide. The main provisions of the guide include: An overview of the arm's length principle and the consequences of non-compliance under Swiss law.
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Poland announces guide on filing transfer pricing reporting forms
On 23 January 2024, Poland’s Ministry of Finance released a notice outlining the process for submitting transfer pricing reporting (TPR) forms for acquired entities. This requirement applies to tax years commencing after 31 December 2021. The
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South Africa releases 2023 tax Acts with significant amendments
On 22 December 2023, the South African Revenue Service officially published the 2023 tax acts, marking a substantial reform in the country's fiscal landscape. The key acts include the Taxation Laws Amendment Act, 2023 (Act 17 of 2023), the Tax
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Indonesia releases revised guidelines for transfer pricing
On 29 December 2023, Indonesia’s Minister of Finance (MoF) released the revised transfer pricing guidelines Regulation No. 172 of 2023 (PMK-172). The updated and consolidated transfer pricing regulations in various chapters, such as: General
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Russia announces transfer pricing changes from 2024
On 27 November 2023, Russia issued Law No. 539-FZ in the Official Gazette, which outlines several amendments to the country’s transfer pricing regime. A summary of several key changes is outlined below: Secondary adjustments treated as
See MoreOECD: 2022 Peer Review Reports on the Exchange of Information on Tax Rulings
On 13 December 2023 the OECD released the 2022 Peer Review Reports on the Exchange of Information on Tax Rulings. The latest annual peer review reports cover 131 Inclusive Framework member jurisdictions and jurisdictions of relevance. The BEPS
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Thailand: TRD updates advance pricing arrangements guidance
In October 2023, Thai Revenue Department (TRD) published updated guidance on advance pricing arrangements (APAs). The guidance on APAs has instructions and requirements for bilateral APAs. The update in the guidance mostly related to the
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United Kingdom: HMRC updates APA guidance
The HMRC has recently updated its guidance (INTM 422000 et seq) on Advance Pricing Agreements (APAs). The updated guidance provides more comprehensive information, particularly in terms of the formal process and HMRC's expected timeframes. These
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Israel releases Guidance on MAP and APA procedures
On 17 August 2023, the Israel Tax Authority (ITA) released Tax Circular No. 1/2023, which provides guidance for mutual agreement procedure (MAP), and bilateral advance pricing agreement (APA) requests. The new circular replaces the guidance of
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South Africa publishes a draft legislation to implement APA program
On 31 July 2023, the National Treasury of South Africa proposes a draft legislation to implement advance pricing agreement (APA) program. An APA program offers taxpayers an enhanced level of assurance when engaging in significant international
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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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US: IRS releases interim guidance on review and acceptance of APA submissions
On 25 April 2023, the Internal Revenue Service (IRS) published a memorandum providing guidance to employees of the Treaty and Transfer Pricing Operations (TTPO) practice area in the Large Business and International Division (LB&I) with respect
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US: IRS issues interim guidance on review and acceptance of advance pricing agreement (APA) submissions
The Internal Revenue Service (IRS) Large Business and International (LB&I) division released a memorandum providing guidance to employees of the Treaty and Transfer Pricing Operations (TTPO) practice area in the Large Business and International
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Luxembourg: Government submits draft bill on transfer pricing and general tax procedures
On 28 March 2023, the Luxembourg government submitted Bill No. 8186 to the Parliament. The bill includes changes in advance pricing arrangement (APA), mutual agreement procedure (MAP), compliance with transfer pricing documentation requirements, and
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