Kenya repeals digital assets tax, expands economic presence tax under Finance Act 2025
The Finance Act 2025 introduces a 10% excise duty on virtual asset transaction fees, expanded SEP tax, a 5-year loss carry forward limit, AMT, and new APA guidelines. Kenya’s President William Ruto signed the Finance Act 2025 into law on 26
See MoreUkraine: Cabinet of Ministers adopts new APA procedures
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,
See MoreVietnam: MoF implements new rules on Advance Pricing Agreements
On 18 June 2021, the Vietnamese Ministry of Finance (MoF) has issued Circular 45/2021/TT-BTC, which sets out new rules on Advance Pricing Agreements in Vietnam. The key measures of the Circular are listed below: Transactions covered by
See MoreCosta Rica: Ministry of Finance issues resolution on APA procedures
On 24 March 2021, the Costa Rican Ministry of Finance released a Resolution No. DGT-R-14-2021, providing new guidelines on advance pricing agreements (APAs). The resolution provides the details guidelines of APAs procedures including definitions
See MoreSouth Korea enacts tax revision bill for 2021
At the end of December 2020, South Korea has enacted a tax revision bill for 2021, which was passed by Korea’s National Assembly on 2 December 2020. The tax revision bill generally effective from fiscal years beginning on or after 1 January 2021.
See MoreTurkey publishes transfer pricing General Communiqué No. 4
On 1 September 2020, the Turkish Revenue Administration has published transfer pricing General Communiqué No. 4 on disguised profit distribution in the Official Gazette No. 31231. The Communiqué explains information regarding new transfer pricing
See MoreGreece: Government publishes a Law amending APA rollback rules
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
See MoreGreece: Parliament published two Laws to introduce various changes in transfer pricing context
On 31 July 2020 and on 29 July 2020, the Greek Parliament Officially published two Laws, L. 4714/2020 and L. 4712/2020 respectively regarding various sections of transfer pricing. The two Laws cover the following changes: Tax dispute Resolution
See MoreRussia: Draft law to revise APA procedures
In March 2020, the Russian Ministry of Finance (MoF) released an amended version of a draft law to improve tax control over prices and procedure for entering into advanced pricing agreements (APA). The draft measures are expected to be adopted in
See MoreIndonesia publishes new regulations concerning advance pricing agreements
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
See MorePortugal publishes changes to various Tax Codes
On 18 September 2019, the Portuguese Government officially published the Law no.119/2019. The new law has changed the following provisions: Corporate income tax: The procedure whereby non-resident companies may waive all or part of the
See MoreCanada: CRA publishes 2017 APA Program Report
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.
See MoreMorocco: New procedures for APAs
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
See MoreTurkey: Council of Minister proposes transfer pricing provisions
A draft Communique regarding transfer pricing has been published in Turkey. It generally represents measures of the OECD’s base erosion and profit shifting (BEPS) Action 13 on country-by-country reporting and transfer pricing documentation. The
See MoreGreece: Amendment to TP documentation rules and APAs
A Law naming ‘Law 4410/2016’ has been announced amendments on the Greek Tax Procedure Code, TP Documentation Rules and the legal framework for Advanced Pricing Agreements (APAs). Amendments on TP Documentation The first amendment mentions to the
See MoreIreland published new APA guidelines
The Irish Revenue published bilateral advance pricing agreement guidelines on June 23 relating to the operation of Ireland’s APA program, which is effective for applications received on or after July 1, 2016. The guidance outlines the framework of
See MoreItaly: Published Legislative Decree on Transfer Pricing Issues in the Official Gazette
Italy Published Legislative decree n. 147 in the official gazette on 22 September 2015 with a view to provide investors with certainty arising from their investment plan. As per the published Legislative decree, expenses relating to the transactions
See MoreItaly: Draft legislative decree introduces advance pricing agreement rollback provision
A draft legislative decree was approved by the Italian Government on 21 April 2015 introducing an advance pricing agreement (APA) rollback provision and provisions relating to costs of transactions with tax havens. The draft decree introduces
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