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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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
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Kazakhstan updates transfer pricing procedures, introduces new local and master file forms
Kazakhstan has issued Order No. 633 of 19 September 2024, which updates Order No. 1104 from 24 December 2018 concerning the forms and procedures for submitting local files, master files, and Country-by-Country (CbC) reports; and introduced new forms
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
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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
See MoreEU Commission consults CbCR template, electronic formats
The European Commission (EC) initiated a public consultation regarding draft legislation for a common template and electronic formats for public country-by-country (CbC) reports on 1 August 2024. Large multinational corporations operating in the
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Belgium updates transfer pricing documentation forms, filing requirements
Belgium has published three new Royal Decrees of 16 June 2024 on 15 July, 2024, announcing revisions to the Local File Form (275. LF), the Master File Form (275. MF), and Country-by-Country Reporting (“CbCR”) Notification Form (275 CBC
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Italy approves draft public CbCR legislative decree
Italy’s Council of Ministers passed the draft decree introducing Public Country-by-Country Reporting (PCbCR) on 10 June, 2024. It amends Directive 2013/34/EU of 26 June 2013 (Accounting Directive), which pertains to the reporting of income
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France: Tax authority updates transfer pricing guidelines for SMEs
On 22 November 2023, the French tax authority published an updated transfer pricing guide for small and medium-sized enterprises (SMEs). The guide covers a wide range of topics, including the concept of transfer pricing, the arm's length principle,
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Poland introduces new electronic templates to report transfer pricing
On 17 October 2023, the Polish Ministry of Finance released new electronic templates for transfer pricing reporting on its website. These templates include: Personal Income Tax Transfer Pricing Report - TPR-P(5) Corporate Income Tax
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Singapore updates list of jurisdictions under MCAA-CbC
On 20 July 2023, the Inland Revenue Authority of Singapore (IRAS) updated the list of jurisdictions participating under the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports. Aruba has been
See MorePuerto Rico: Treasury Department clarifies guidance on transfer pricing studies
On 20 September 2021, the Puerto Rico Treasury Department (PRTD) has issued Administrative Determination (AD) No. 21-08, which amends AD No. 21-05 of 11 May 2021. The AD 21-08 clarifies guidance on submitting transfer pricing studies (TPS). AD
See MoreSingapore publishes transfer pricing guidance in response to the Covid-19 outbreak
On 8 September 2020, the Inland Revenue Authority of Singapore updated its website by including guidance regarding transfer pricing in response to the Covid-19 pandemic. The guidance is provided in a following question and answering
See MoreThailand: National Legislative Assembly publishes revised draft transfer pricing act
On 27 September 2018, National Legislative Assembly released the revisions to the draft Transfer Pricing Act (the draft TP Act). The revenue threshold for subject to transfer pricing documentation is THB200 million (US$6 million) per year
See MoreKazakhstan: Tax Law Reforms for the year 2018
The Kazakh President, signed a series of laws on 25 December 2017 regarding taxes and other mandatory payments, introduction of tax code, law on amendments to other Acts etc. Most provisions of the new tax code and the tax amendments effects from 1
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 MoreFrance-Approved Finance Bill 2016 and amended Finance Bill 2015
The French Parliament approved the Finance Bill for 2016 and and the amended Finance Bill for 2015 on 17 December 2015. The Finance Bill enacts the country-by-country (CbC) reporting requirement into the legislation of France. From 1 January 2016
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