Malta seeks comments on draft Transfer Pricing Rules

December 29, 2021

On 22 December 2021, Malta’s Commissioner for Revenue (CFR) has published draft Transfer Pricing Rules on its website for public consultation. The consultation period will end on 28 February 2022, and the draft Transfer Pricing Rules shall come

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Ukraine: Cabinet of Ministers adopts new APA procedures

November 04, 2021

On 28 October 2021, the Cabinet of Ministers of Ukraine has adopted new procedures of preliminary coordination of advance pricing agreements (APAs) in controlled transactions, as a result of which agreements on preliminary coordination of pricing,

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Greece: Government publishes a Law amending APA rollback rules

September 04, 2020

On 31 July 2020, the Government Officially published Law 4714/2020, which amends the existing advance pricing agreement (APA) provisions. The new Law helps to comply with the minimum standard under Action 14 of the OECD’s base erosion and profit

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Indonesia publishes new regulations concerning advance pricing agreements

April 02, 2020

On 18 March 2020, the Indonesian Ministry of Finance released 22/PMK.03/2020 which updates the Advance Pricing Agreements (“APA”) regulations. The new regulations, effective 18 March 2020, include the following amendments: Previously

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India deposits ratification instrument for MLI

June 30, 2019

On 25 June 2019, India has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). According to Article 34, Paragraph 2 of the MLI, with

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Portugal approves MLI

June 26, 2019

On 21 June 2019, the Portugal's parliament approved the resolution for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). After the ratification process,

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Russia deposits ratification instrument for MLI

June 20, 2019

On 18 June 2019, the Russian Federation has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). According to the date of deposit,

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Canada: CRA publishes 2017 APA Program Report

July 17, 2018

The Canada Revenue Agency (CRA) has published an annual report on its APA program since the 2001 to 2002 fiscal year. Since 2016, the annual report has been based on a calendar year, whereas the previous annual reports were based on a fiscal year.

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Russia publishes bilateral and multilateral APA Procedure

May 10, 2018

On 3 May 2018, Russia published Decree No. 60 on the Official Gazette, which approves the procedures for the conclusion of advance pricing agreements (APAs).  The Russian Finance Ministry delegated the competent authority powers with respect to

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Turkey: General Communiqué No. 3 regarding APAs publishes in the official gazette

February 25, 2018

The General Communiqué No. 3 regarding application process of Advance Pricing Agreements (APAs) was published on December 7, 2017 in the official gazette. It was entered into force on the similar day of its publication in the official gazette. The

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Turkey: Revenue Administration publishes draft Communiqué 3 on APAs

October 25, 2017

The Revenue Administration published draft General Communiqué No. 3 on October 24, 2017 regarding transfer pricing. This provides amendments to Section 6 of General Communiqué No. 1. According to draft General Communiqué No. 3, definitions of

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Morocco: New procedures for APAs

September 10, 2017

Morocco published a Decree No. 2.16.571 of 3 July 2017 in the Official Gazette No. 6594 on August 10, 2017 that describes the procedure for concluding advance pricing agreements (APAs). This decree was published in Arabic language. For example, a

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Cyprus: Council of Ministers approves Multilateral Instrument signing to OECD

April 15, 2017

According to a press release issued by the Finance Ministry, the signing of the “Multilateral Instrument” has been approved by the Council of Ministers on April 5, 2017. Therefore, Cyprus is going to sign the ‘Multilateral Convention to

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Russia: Publishes the draft procedure on multilateral APAs

March 15, 2017

The Russian Finance Ministry on 3 March 2017, published a draft Procedure outlining the process for handling multilateral Advanced Pricing Agreements (APAs). The Procedure is intended to enable a taxpayer to conclude an APA in relation to a foreign

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Uruguay-Bill on adoption of CbC reporting, Master file documentation and the availability of bilateral and multilateral APAs

August 15, 2016

The Uruguay Government has submitted to Congress a tax bill including adoption of the OECD’s recommendations for Country-by-Country (CbC) reporting following the scope of information to be provided under the Base Erosion and Profit Shifting (BEPS)

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Ukraine: Cabinet of Ministers adopts new advance pricing agreement procedures

August 01, 2015

Ukraine’s Cabinet of Ministers published Resolution No. 504 on 25 July 2015 regarding conclusion of advance pricing agreements (“APA”) in respect of controlled transactions for transfer pricing purposes. The new Resolution replaces the former

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