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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Brazil releases normative instruction for its new transfer pricing rules
On 28 September 2023, Brazil published Normative Instruction Nº 2,161 (IN 2,161/23) that governs Brazil’s recently established new transfer pricing law. The new legislation explicitly adopts the arm's length principle into the Brazilian legal
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Poland releases notice providing clarification on TPD documentation
On 4 September 2023, the Polish Official Gazetted a notice aimed at providing comprehensive clarification regarding the regulations governing transfer pricing documentation for corporate income tax purposes. This notice encompasses several key
See MoreFrance updates list of exempted countries for CbC report local filing requirements
On 13 August 2023, Government published the Decree which amends the Order 6 July 2017 pursuant to II of Article 223 quinquies C of the General Tax Code. The new Decree updates the the list of country exemption from local filing Country-by-Country
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Cyprus: Tax department issues transfer pricing simplification measures
On 6 July 2023, the Cyprus Tax Department released a new circular (6/2023) entitled "Simplification measures for persons exempt from the obligation to maintain a Cyprus local file". The Circular provides guidance for persons exempt from the
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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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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
See MorePoland: MoF publishes draft decree changing the TP reports
On 25 April 2022, the Polish Ministry of Finance published a draft decree to change the scope of data and information to be disclosed via transfer pricing reports. The changes introduced by the draft decree include limiting the scope of transfer
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 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
See MoreThailand: New documentation requirement introduces Local file
On 30 September 2021, the Director-General of the Thai Revenue Department issued guidance Notification No. 407 regarding transfer pricing (TP) documentation requirements for the information and documentation for the Local file and exemption from
See MoreAustralia extends Local file Part A lodgment
The Australian Taxation Office (ATO) has provided 31 December 2020 early balancing entities additional time until 30 August 2021 to lodge Part A of their 2021 local file if they indicate in their tax return they are taking up the local file
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