Albania introduces new income tax framework, bringing significant changes from 2024
On 20 September 2023, Albania released Income Tax Instruction No. 26 in the Official Gazette, laying the groundwork for the enforcement of Income Tax Law No. 29/2023. The Income Tax Law No. 8438/1998 was repealed and replaced by Law No. 29/2023,
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Australia extends deadline for submitting CbC reports, Master file & Local file
The Australian Tax Office (ATO) has announced that taxpayers with country-by-country (CbC) reporting obligations for the year ending 31 December 2022 will now have until 31 January 2024 to submit their reports. This extension applies to the CbC
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Greece issues a draft bill on CbC reporting requirements for public consultation
On 19 October 2023, the Greek Ministry of Development issued a draft bill for consultation that provides for the introduction of public Country-by-Country (CbC) reporting in compliance with Directive (EU) 2021/2101. The bill conforms to the
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Egypt releases explanatory instructions on transfer pricing reporting obligations
On 19 September 2023, the Egyptian Tax Authority issued Explanatory Instruction No. 78 introducing mandatory transfer pricing reporting obligations for related party transactions. Accordingly, the Tax Authority has set deadlines for submitting
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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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Belgium approves draft law on public CbC reporting
On 13 October 2023, the Belgian Council of Ministers passed the preliminary draft law for transposing the EU public country-by-country (CbC) reporting directive (2021/2101). According to the new public (CbC) rules, groups with consolidated
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Chile declares revised tax return deadlines for 2024
On 4 October 2023, the Chilean federal tax agency published Resolution No. 116 with revised filing deadlines of different forms for the 2024 tax year. The deadlines of forms are as follows: March 1: Forms 1811, 1822, 1834, 1891, 1900, 1902,
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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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Slovenia: Tax agency declares CbC reporting deadline
On 10 October 2023, the Slovenian Tax Agency (Financial Administration) declared that country-by-country (CbC) reports for the fiscal year ending on 31 December 2022 , submission is a mandatory requirement by 31 December 2023. Taxpayers must submit
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Cyprus announces expected effective date of CbC exchange agreement with the US
On 5 October 2023, the Cyprus Tax Department issued a notice regarding the anticipated implementation date of the agreement for the exchange of Country-by-Country (CbC) reports with the United States alongside the local filing obligations. The
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Latvia publishes law transposing public CbC reporting into domestic law
On 27 September 2023, the Latvian government released the "Information on Revenue and Income Tax Disclosure Law" in the Official Gazette. This law outlines the framework for the adoption of public Country-by-Country (CbC) reporting, aligning Latvia
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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
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Morocco releases latest CbC reporting guidance
The Moroccan General Directorate of Taxation (DGI) has recently released latest Country-by-Country (CbC) reporting guidance. Morocco implemented CbC reporting obligations starting from 1 January 2021, in accordance with the Finance Law for 2020.
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Luxembourg implements public CbC reporting
On 22 August 2023, Luxembourg published Law of 15 August 2023 in the Official Gazette implementing public Country-by-Country (CbC) reporting in compliance with Directive (EU) 2021/2101. The Law conforms to the directive and sets the public
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Portugal implements CbC reporting requirements
On 23 August 2023, the Portuguese government published Decree-Law No. 73/2023 in the Official Gazette, which establishes the requirements for public country-by-country (CbC) reporting by multinational enterprises (MNEs). The new rules on public
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UK updates transfer pricing documentation requirements
The United Kingdom (UK) has published the Transfer Pricing Records Regulations 2023, which updated transfer pricing documentation requirements by introducing Local file and Master file requirements. The UK has officially updated its transfer
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France 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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Paraguay upgrades transfer pricing documentation process
On 20 July 2023, the tax authority of Paraguay (SET) issued General Resolution No. 134 of 18 July 2023, that introduces an exceptional mechanism for the submission of the technical transfer pricing study (Estudio Técnico de Precios de Transferencia
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