Egypt raises materiality threshold for master file and local file for 2024
On 15 February 2024, Egypt published the Ministerial Decree No. 52 of 2024 in the Official Gazette, providing updated transfer pricing documentation requirements for Egyptian taxpayers. This decree came into effect on 22 February 2024. In this
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Australia holding public consultation on updated public CbC reporting legislation
On 12 February 2024, the Australian Treasury announced it is conducting an additional public consultation regarding implementing new requirements for publishing selected tax information on a Country-by-Country (CbC) basis or public CbC reporting.
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Egypt preparing draft for new income tax law
Egypt’s Minister of Finance for Tax Policy and Reforms has announced plans to draft a new iteration of the Income Tax Law. The details of the new law has been fully published, but the main proposals of the new law include: A focus on
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Estonia passes draft law for delaying pillar 2 global minimum tax and public CbC reporting
On 8 February 2024, Estonia's Ministry of Finance, in a release announced that it passed the draft legislation to postpone the implementation of the Pillar 2 global minimum tax until the year 2030. Until that time, the companies that fall within the
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Cyprus revises thresholds for transfer pricing documentation
On 1 February 2024, the Cyprus Tax Department released updated thresholds regarding the requirement for taxpayers to prepare a Cyprus Local File for intercompany transactions covered by Section 33 of the Income Tax Law (ITL). These revised
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Belgium implements public country-by-country reporting (CbCR)Â
On 26 January 2024, Belgium announced the introduction of public country-by-country reporting (CbCR) in the Official Gazette. The new law aligns with the EU Directive 2021/2101 or the EU Public CbCR Directive. On 1 December 2021, the European
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Dominican Republic: DGII enables e-portal for CbC reports submission
On 12 January 2024, the Directorate General of Internal Revenue (DGII) in the Dominican Republic released Notice 01-2024, notifying the availability of the reporting portal for Country-by-Country (CbC) reports. The obligation for Country-by-Country
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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
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Italy 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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Ukraine introduces CbC reports filing for the first time
On 11 January 2024, the State Tax Service of Ukraine, in a release announced it has introduced Country-by-Country (CbC) reporting for the parent companies of the international groups of companies for the first time in the country. The CbC reporting
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Qatar extends deadline for CbC reports submission
Qatar’s tax authority announced that it is extending the deadline for Qatar-based companies to submit their country-by-country (CbC) reports for the fiscal year 2022 and CbC notifications for the fiscal year 2023. The new deadline is 31 January
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Poland publishes guidance on transfer pricing, base interest rates, and margin rates
On 29 December 2023, Poland’s Ministry of Finance released the guide on submitting transfer pricing information, which includes: Detailed FAQs related to the obligation to submit transfer pricing information; entity identification
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Ireland publishes new guidance on requesting TP documentation
On 18 December 2023, the Irish Revenue issued eBrief No. 261/23 providing a new Tax and Duty Manual Part 35a-01-05 - Requests for Transfer Pricing (TP) Documentation. This Tax and Duty Manual documents the operational policy of the Transfer
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Belgium enacts law on public CbC reporting
On 21 December 2023, the Belgian Chamber of Representatives passed a legislation for enacting the public Country-by-Country (CbC) reporting as required by Directive (EU) 2021/2101. The Directive mandates that a company is subject to public
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Colombia announces new TP documentation deadlines for 2023 and later
On 22 December 2023, Columbia released Decree 2229, introducing revised deadlines for submitting various forms of transfer pricing documentation. These include the informative declaration, country-by-country (CbC) notification, Local file, Master
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Iceland announces CbC notification deadline for 2023
On 19 December 2023, Iceland published Notice 1525/2023 in the Official Gazette. The notice stipulates that the CbC report notification for the 2023 fiscal year must be submitted within one month from the year's end (by 31 January 2024, for the
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Kazakhstan’s Transfer Pricing Legislative Amendments 2023
Kazakhstan is undergoing a pivotal transformation in its transfer pricing framework, marked by the Majilis' approval of substantial amendments to the existing legislation. The aim is to curb revenue losses, prevent capital outflow, and align with
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Netherlands: Senate passes public CbC reporting bill
The Dutch Senate (upper house of parliament) has passed the bill for implementing public Country-by-Country (CbC) reporting as required by Directive (EU) 2021/2101. The bill facilitates the partial implementation of Council Directive (EU) 2021/2101,
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