UK: Consultation on Transfer Pricing Records Regulations 2023
On 21 December 2022 the UK issued for consultation the draft regulations on Transfer Pricing Documentation, inviting comments from interested parties by 31 January 2023. The draft statutory instrument would require multinationals operating in the
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UAE publishes new corporate tax law
On 9 December 2022, the UAE Ministry of Finance (MoF) released the Federal Decree-Law No. 47 of 2022 on business taxation to enact a new Corporate Tax Law in the UAE. The new law has been supplemented with Frequently Asked Questions (FAQs). The
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Israel gazettes amendments to transfer pricing regulations
On 22 September 2022, the Israeli Official Gazette published the Income Tax Regulations 2022, amending the Income Tax Ordinance, which adopted on 30 June 2022 for the introduction of the three-tiered transfer pricing documentation requirements of
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Australia updates local file and master file guidelines for 2022
On 9 August 2022, the Australian Taxation Office (ATO) updated guidance on the Local and Master file for 2022 along with instructions. The guidance applies to reporting periods beginning on or after 1 January 2021. The local file must be
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UK plans to introduce three-tiered documentation requirements
On 20 July 2022, the UK Government published draft legislation as part of the Finance Bill 2022-23 which will make it a requirement for large multinational businesses operating in the UK to keep and retain transfer pricing (TP) documentation in a
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Israel introduces three-tiered TP documentation requirements
On 30 June 2022, the Israeli Parliament passed legislation to amend Section 85A of the Income Tax Ordinance (ITO) and its regulations, by introducing three-tiered transfer pricing documentation requirements of BEPS Action 13. The legislation
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Kenya: Major changes in transfer pricing rules under Finance Act 2022
On 8 July 2022, the Kenyan Finance Act 2022 was gazetted which was signed into law by the President on 21 June 2022. The law introduced a number of changes to the transfer pricing regulatory framework in Kenya that will have far-reaching
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Saudi Arabia issues draft Transfer Pricing Bylaws for public consultation
On 4 July 2022, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued a draft of Transfer Pricing (TP) Bylaws and invited public consultation. The public consultation period is open until 30 July 2022. The final Transfer Pricing Bylaws
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Cyprus: Parliament adopts new transfer pricing legislation
On 30 June 2022, the Cyprus House of Representatives enacted detailed transfer pricing legislation amending the Cyprus Income Tax Law (ITL) and the issuance of Regulations. The amendment includes the new TP documentation requirements and a framework
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Qatar: Tax authority updates master file and local file submission deadline
On 8 June 2022, the General Tax Authority (GTA) of Qatar issued Decision No. 10 of 2022 that amends certain provisions in Decision No. 4 of 2020 to clarify that the deadline for filing the transfer pricing Master File (MF) and Local File (LF) is 60
See MoreUkraine clarifies transfer pricing requirements under martial law
On 2 June 2022, the Ukrainian State Tax Service (STS) has published a notification that clarifies transfer pricing requirements under martial law conditions in Ukraine, taking into account of COVID-19 situation. Transfer pricing
See MoreKenya: Transfer pricing measures in Finance Bill 2022
On 12 April 2022, the Finance Bill 2022 was presented in the National Assembly of Kenya, which provides following tax measures related to transfer pricing. The Bill aims to amend Section 18(A) of the ITA to include transactions between residents
See MoreDenmark amends the transfer pricing documentation rules
On 31 January 2022, the Danish Ministry of Finance issued updated guidance regarding amendments to the transfer pricing rules requiring the submission of the transfer pricing documentation within 60 days of the due date for filing the tax return,
See MoreDominican Republic: DGII publishes thresholds for TP documentation and some tax issues
The Directorate General of Internal Revenue (DGII) has published Resolution No. DDG- AR1-2021-00001, which provides the general multiplier for inflation adjustments for the fiscal year ending 31 December 2021, including new transfer pricing
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Colombia issues decree on the tax return and TP documentation deadline in 2022
On 20 December 2021, the Colombian Ministry of Finance and Public Credit has issued Decree 1778 specifying the deadlines for filing and payment of the tax return (declaration) in 2022 and the deadline for transfer pricing (TP) documentation,
See MoreJordan: ISTD publishes transfer pricing documentation forms
On 2 January 2022, the Jordan Income and Sales Tax Department (ISTD) has published new transfer pricing documentation forms (Arabic) in line with Regulation No. 40 of 7 June 2021. ISTD has published forms for Local File, Master File,
See MoreCyprus: Tax department extends the deadline for submitting local CbCR reporting
On 20 December 2021, the Cyprus Tax Department published an announcement informing that the deadline for submission for local CbCR reporting due to the secondary filing mechanism (including Equivalent reporting) for the year 2020 is the 31st of
See MoreItaly clarifies TP documentation requirements
On 26 November 2021, the Italian Tax Authorities issued Circular No. 15 providing clarifications on the regulations introduced on 23 November 2020 regarding the content and validity of the elective transfer pricing (TP) documentation available to
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