Germany mandates transaction matrix transfer pricing documentation requirement
Germany’s Ministry of Finance released a decree outlining the requirements for the “transaction matrix,” a new component of transfer pricing documentation under section 90(3) of the Fiscal Code (AO) on 2 April 2024. The transaction matrix
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Israel clarifies CbC reporting rules for MNEs
The Israel Tax Authority (ITA) issued Income Tax Circular No. 1/2025 on 11 February 2025, which clarifies amendments to the Income Tax Ordinance. The amendments pertain to transfer pricing and country-by-country (CbC) reporting requirements. The
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Australia: ATO issues guidance for local file and master file, private property and construction sector company transfer pricing for 2025
The Australian Taxation Office (ATO) has published updated guidance on the local and master file requirements – which applies to reporting periods beginning on or after 1 January 2024 –, and transfer pricing guidance for the private property and
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European Commission issues final rules for CbC reporting directive
The European Commission has published the final version of the Commission Implementing Regulation (EU) 2024/2952 of 29 November 2024 in the Official Journal of the EU on 2 December 2024. This document establishes a common template and electronic
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EU releases updated public CbC reporting forms
The European Commission (EC) published a revised regulation that provides the common template and electronic reporting formats for the EU public country-by-country (CbC) reporting directive on 21 October 2024. This follows after the conclusion of
See MoreAustralia: ATO extends CbC reporting deadlines
The Australian Taxation Office (ATO) announced, on 13 November 2024, an extension for the filing deadline of country-by-country (CbC) reporting entities for the year ending 31 December 2023. The deadline has been extended until 31 January
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Hungary approves CbCR IGA with the US
Hungary’s parliament passed the 2024 Hungary-US Agreement on the Automatic Exchange of Country-By-Country (CbC) Reports on 4 November 2024. The CbC agreement was signed on 15 July 2024 by Hungary and on 1 August 2024 by the US. The newly
See MoreEuropean Commission updates draft rules for public CbC reporting template, digital formats
The European Commission has released a revised draft of the Commission Implementing Regulation, establishing a standardised template and electronic reporting formats for Public Country-by-Country (CbC) reporting within the EU. This initiative
See MoreGermany passes Fourth Bureaucracy Relief Act, cuts accounting document retention and updates transfer pricing rules
Germany’s Federal Council (Bundesrat) passed the Fourth Bureaucracy Relief Act on 18 October 2024 following its approval by the Bundestag (lower house of parliament) on 26 September 2024. One key aspect of the Act is that it reduces
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Turkey updates transfer pricing communiqué to align with new CbC reporting deadlines
Turkey’s Ministry of Treasury and Finance released General Communiqué No. 5 on Transfer Pricing on 17 October 2014. This Communiqué amends General Communiqué No. 1 on Transfer Pricing and aligns it with new deadlines for Country-by-Country
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Albania implements country-by-country reporting legislation
Albania enacted regulations on 11 August 2024, concerning country-by-country (CbC) reporting, outlining specific rules and procedures that ultimate parent entities and constituent entities of a multinational enterprise (MNE) group must follow
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Italy: Country File of transfer pricing documentation must be submitted in Italian
The Italian Revenue Agency issued its response to Ruling No. 174 on 21 August 2024, clarifying that the Italian the Country File (National Documentation) must be prepared and submitted in Italian language upon request. The Country File (National
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Singapore: IRAS publishes the seventh edition of the e-tax guide on transfer pricing
On 14 June 2024, the Inland Revenue Authority of Singapore (IRAS) published the Seventh Edition of its e-tax guide on transfer pricing. The most important changes are summarised as follows: Enhanced clarity on working capital adjustment The
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Belgium issues royal decree on public CbC reporting details
On 6 June, 2024, the Belgian government released the royal decree of 18 April, 2024 (Dutch/French). It amends the royal decree of 29 April, 2019, regarding implementation of the Belgian Code for Companies and Associations (BCCA). The new decree
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Algeria extends deadline for 2023 tax returns and transfer pricing documentation
On 21 April 2024, the Directorate General of Taxes in Algeria announced via a communiqué an extension for the deadline to submit annual tax returns (G4 and G11) and the annual personal income declaration (G1) for the fiscal year 2023. As per the
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Germany: MOF issues updated draft guidance on virtual currency transactions
On 6 March 2024, the German Ministry of Finance (MOF) released revised draft guidance concerning the compliance and documentation criteria for transactions involving virtual currency and tokens. This comes after the issuance of a final decree in May
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Malta issues guidelines for transfer pricing rules
On 19 January 2024, Malta's Commissioner for Revenue published Guidelines in relation to the Transfer Pricing Rules. These guidelines are issued in terms of Article 96(2) of the Income Tax Act (Chapter 123 of the Laws of Malta) and are to be read in
See MoreItaly announces new deadline for transfer pricing documentation
On 12 January 2024, Italy published the Legislative Decree no. 1/2024 in the Official Gazette. The Decree details the simplification and rationalization of certain tax rules, including introducing a new tax calendar. From 2 May 2024, taxpayers
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