Algeria announces supplementary finance law for 2023
In November 2023, Algeria published the Supplementary Finance Law for 2023 in the Official Gazette. The key tax measures of the law include: A new transfer pricing declaration obligation has been introduced, requiring taxpayers to submit an
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Ecuador releases updated technical sheet for standardizing the analysis of transfer pricing
On 22 November 2023, the Ecuadorian Tax Authority released a new edition of the technical sheet for the standardization of transfer pricing analysis, effective for fiscal year 2023. This updated document introduces significant changes to filing
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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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UK: HMRC publishes guidance on transfer pricing records for PEs
The United Kingdom (UK) HRMC has issued guidance on the transfer pricing records requirements for permanent establishments (PEs) in accordance with the amendments made by Finance (No. 2) Act 2023. The Local files and Master files requirements for
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Russia: FTS introduce a list of jurisdictions not exchanging CbC reports
The Russian Federal Tax Service (FTS) released a list of jurisdictions that have repeatedly failed to exchange Country-by-Country (CbC) reports electronically with Russia. In cases of systemic exchange failure, a constituent entity within Russia
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Greece implements public CbC reporting
On 14 November 2023, Greece published Law No. 5066/2023 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 reporting
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Czech Republic approves tax reform measures for FY 2024
The Parliament of the Czech Republic approved the Act on the Consolidation of Public Budgets. Most of the proposed amendments are scheduled to take effect from 1 January 2024. Some of the key tax measures are following: The corporate income tax
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Taiwan: MOF reminds taxpayers to submit master file and CbC report by 31st December 2023
On 10 November 2023, Taiwan’s Ministry of Finance (MOF) issued a press release as a reminder to the taxpayers to submit master file and country-by-country (CbC) report. The profit-seeking enterprises that meet the conditions and use the
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Singapore Gazettes Order Declaring MCAA-CbC
On 6 November 2023, the Singaporean Official Gazette issued Order No. S 714 confirming the effective dates for the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country Reports (CbC) with specific jurisdictions.
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Hungary approves new CbC exchange agreement with the US
On 2 November 2023, Hungary formally approved signing a new Country-by-Country (CbC) exchange agreement with the United States. The agreement—Decree No. 1482/2023—was published in the Official Gazette. This follows the previous CbC exchange
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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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