Argentina issues transfer pricing rules for SPV transactions under large investment incentive regime
Under the new rules, SPVs must annually file transfer pricing analyses with the ARCA for both local and international transactions, including those in low- or no-tax jurisdictions, and may engage in Contribution and Cost Sharing
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Chile updates tax compliance law, introduces changes to GAAR, transfer pricing, and CFC
Chile's Internal Revenue Service (SII) has announced that the Law on Compliance with Tax Obligations (Law No. 21.713) has been published in the Official Gazette on 24 October 2024. General and Special Anti-Avoidance Rules changes The General
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UN Tax Committee: Issues in Extractive Industries Taxation
On 15 October 2024 the UN Tax Committee discussed developments in their work on extractive industries taxation. The work of the relevant subcommittee has focused on the energy transition; the valuation of mining products for tax purposes; and tax
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Cyprus publishes FAQs on new transfer pricing rules
The tax authority has published additional frequently asked questions (FAQs) numbered 25 – 43 to provide clarity on specific provisions of the new transfer pricing rules in Cyprus. Notably, FAQ 25 clarifies that taxpayers do not need to
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OECD publishes model agreement for Pillar One Amount B
The Organisation for Economic Co-operation and Development (OECD) announced the release of a Model Competent Authority Agreement (MCAA) concerning Amount B of Pillar One, a part of the OECD/G20 Inclusive Framework on BEPS yesterday, 26 September
See MoreOECD: Report on Simplified Peer Review of Egypt under BEPS Action 14
On 16 September 2024 the OECD published the simplified peer review report on Egypt under Action 14 of the project on base erosion and profit shifting (BEPS). The report sets out the results of Stage 1 of the simplified peer review of the
See MoreOECD: Report on Simplified Peer Review of Nigeria under BEPS Action 14
On 16 September 2024 the OECD published the simplified peer review report on Nigeria under Action 14 of the project on base erosion and profit shifting (BEPS). The report sets out the results of Stage 1 of the simplified peer review of the
See MoreOECD: Report to the July Meeting of G20 Finance Ministers
On 25 July 2024 the OECD published the report prepared for the meeting of G20 Finance Ministers and Central Bank Governors held in Brazil from 25 to 26 July 2024. The report notes some recent developments in important areas of international tax
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OECD: Definition of qualifying jurisdictions for application of Amount B of Pillar One
On 17 June 2024 the OECD Inclusive Framework on BEPS released supplementary elements relating to the report of 19 February 2024 on Amount B of Pillar One. Under the streamlined and simplified approach under Amount B, a pricing matrix is used to
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MoF in Ethiopia issues new transfer pricing directive
The Ethiopian Ministry of Finance (MoF) released Directive No. 981/2024 (referred to as "The Directive"), introducing new transfer pricing regulations, concerning the pricing of international and domestic transactions between related persons whose
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Colombia: CUP method valid for commodity transactions without quoted prices
The Colombian Tax Authority (DIAN) released Ruling 1118 (Int. 81) of 13 February 2024, which provides clarification of the application of the Comparable Uncontrolled Price (CUP) method for commodity transactions between related parties that do not
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OECD: Secretary General’s Tax Report to G20 Finance Ministers
On 19 February 2024 the OECD published the Secretary General’s tax report to the G20 Finance Ministers and Central Bank Governors for their meeting of February 2024. The report covered important international tax developments since their previous
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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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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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UN Adopts Resolution to Set Up a Framework Convention on Tax
On 22 November 2023 the UN general assembly adopted a resolution to commence the process of setting up a framework convention on tax. The framework convention could ensure that the UN is the main body for decision-making on international tax
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Germany: Bundestag approves draft business tax reform bill
On 17 November 2023, the German lower house parliament (Bundestag) passed a bill that seeks to promote economic expansion, stimulate investment, and make the tax system more user-friendly and equitable. Some of the key provisions of the bill
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OECD: Consultation on Transfer Pricing Issues Relating to Lithium
On 6 November 2023 the OECD and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) released for public consultation a draft toolkit with the title Determining the Price of Minerals: Application to Lithium. The
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