Saudi Arabia releases third edition of transfer pricing guidelines
The Zakat, Tax and Customs Authority (ZATCA) in Saudi Arabia published the third edition of its Transfer Pricing (TP) Guidelines on 29 July 2024, introducing several changes. Key updates include: Exemptions for group companies: Group
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UAE: FTA introduces new guidelines for corporate tax clarifications, APA submissions
In a move aimed at enhancing clarity and support for taxpayers in the UAE, the Federal Tax Authority (FTA) has introduced new guidelines under Decisions No. 4 and No. 5 of 2024. These decisions, which took effect on 1 July and 1 August respectively,
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UAE: FTA announces implementation of advance pricing agreements in Q4 2024
The UAE Federal Tax Authority (FTA) updated Decision No. 4 of 2024 on 12 June 2024, clarifying the future implementation of an advance pricing agreements (APAs) framework in the UAE. Based on the Corporate Tax Law, a person may make an
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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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Ireland: Irish Revenue makes changes to bilateral advance pricing agreement guidelines
On 26 April 2024, the Irish Revenue published eBrief No. 127/24 outlining the updated Tax and Duty Manual Part 35-02-07 Bilateral Advance Pricing Agreement Guidelines. The updated Guidelines take into account international best practices in relation
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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
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OECD: 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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