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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Saudi Arabia: ZATCA approves amendment to the TP Bylaws
On 20 March 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) approved Decision No. 8-2-23 to amend the Transfer Pricing (TP) Bylaws. The approved amendments to the TP Bylaws in Saudi Arabia will expand the scope of the provisions to
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UK: Transfer Pricing and Diverted Profits Tax Statistics
On 7 February 2022 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 2022/22 tax year. The transfer pricing work is an important part of
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Malta implements formal transfer pricing rules
On 18 November 2022, Malta published Legal Notice 284 of 2022 in the Official Gazette implementing transfer pricing rules into Malta’s tax code. These rules shall apply for basis years commencing on or after 1 January 2024 in relation to any
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Hungary submits a draft legislation to Parliament on APA and CbCR
On 18 October 2022, Hungarian Ministry of Finance has submitted a draft legislation to the Parliament proposing the amendments of advance pricing arrangements (APAs) and introduction of public CbC reporting. Effective from 1 January 2023, the
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US: Sixth Circuit affirms taxpayer not liable for penalty upon cancellation of APAs
On 25 August 2022, the U.S. Court of Appeals for the Sixth Circuit affirmed in part and reversed in part a decision of the U.S. tax court regarding the transfer pricing case of Eaton Corp. v. Commissioner. Facts of the case Eaton Corporation
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Lithuania amends the APA rules
Recently, the State Tax Inspectorate of the Ministry of Finance of the Republic of Lithuania revised the Lithuanian Advance Pricing Agreements (APAs), which came into effect on 31 March 2022. Among other changes, the amendments also provide for
See MoreUK: Transfer Pricing and Diverted Profits Tax Statistics
On 28 April 2022 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 2020/21 tax year. HMRC is anxious to reduce the amount of the tax gap,
See MorePoland: MOF extends the deadline for APA implementation report
On 23 March 2022, the Polish Ministry of Finance has published a press release extending the deadline for APA implementation report to 30 June 2022. The deadline extension applies to companies with financial years ending between 1 December 2021 and
See MoreNigeria: FIRS posts digital FAQs regarding transfer pricing
On 15 March 2022, the Federal Inland Revenue Service (FIRS) made a post of frequently asked questions and answers (FAQs) related to transfer pricing (TP) through online. This includes applicable regulations and their scope; documentation
See MoreSlovenia updates the TP guidelines
On 31 January 2022, the Slovenian Ministry of Finance updated the transfer pricing (TP) guidelines. The revised guidance includes the new documentation requirements and procedures for determining income and transfer pricing, including for
See MoreAustralia: ATO declares review of APA program
On 12 January 2022, the Australian Taxation Office (ATO) has announced that it is undertaking a review of its advance pricing arrangement (APA) program. The APA program provides a valuable service delivering certainty on dealings with
See MoreMalta seeks comments on draft Transfer Pricing Rules
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
See MoreSouth Africa: SARS opens a public consultation for an APA program
On 10 December 2021, the South African Revenue Service (SARS) made an announcement for inviting public comments for a model and draft legislation regarding Advance Pricing Agreement (APA) system until the end of January 2022. The draft model is
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