UAE: MoF issues decision on TP documentation requirements
On 11 May 2023, the United Arab Emirates (UAE) Ministry of Finance (MoF) issued Ministerial Decision No. 97 of 2023 on the requirements for maintaining transfer pricing (TP) documentation. Federal Decree Law No (47) of 2023 on the Taxation of
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Kenya: Transfer pricing tax measures in Finance Bill 2023
On 28 April 2023, the Cabinet Secretary of the Kenya Ministry of Finance submitted the Finance Bill 2023 (the Bill) to Parliament, which provides the following tax measures related to transfer pricing. The bill proposes to prohibit taxpayers from
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Saudi Arabia: ZATCA approves amendment to the TP Bylaws
On 20 March 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) approved Decision No. 8-2-23 to amend the Transfer Pricing (TP) Bylaws. The approved amendments to the TP Bylaws in Saudi Arabia will expand the scope of the provisions to
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Australia releases draft legislation on public CbC reporting requirement
On 6 April 2023, the Australian Treasury Department issued draft legislation outlining the implementation of public country-by-country (CbC) reporting requirements for specific tax-related information to be disclosed by multinational enterprises
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Lithuania publishes draft law to transpose public CbC reporting
On 7 March 2023, the government of Lithuania issued a draft law to transpose the EU Public Country-by-Country (CbC) Reporting Directive into domestic law. According to the Directive, the upcoming legislation will mandate multinational corporations
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Greece: Public Revenue Authority publishes frequently asked question on CbC Report
On 24 February 2023, the Public Revenue Authority released frequently asked question (FAQ) document in English providing the elaborate description of country-by-country (CbC) reporting, related OECD Country-by-Country reporting guidelines and
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Luxembourg: Government presents a draft bill to the Parliament on public CbC reporting
On 24 February 2023, the Luxembourg government presented Bill no. 8158 to the Parliament to implement public Country-by-Country (CbC) reporting in compliance with Directive (EU) 2021/2101. The bill conforms to the directive and sets the public
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Cyprus: Tax department issues FAQs on new transfer pricing legislation
On 10 February 2023, the Cyprus Tax Department published a set of Frequently Asked Questions (FAQs) aiming to clarify certain provisions of the new transfer pricing rules approved in June 2022 with effect from 1 January 2022, including Local File
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Israel publishes a new CbC Notification form
The Israeli Tax Authority (ITA) has recently released a new Notification Form 1585 for the disclosure of information related to Country-by-country reporting (CbCR). This includes providing details on group revenues, identifying the Ultimate Parent
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Hungary: MoF publishes decree amending TP rules on transfer pricing documentation
On 28 December 2022, the Hungarian Ministry of Finance published Decree 27/2022 (XII.28) which amends the Decree 32/2017 (X.18) on the documentation requirement related to the determination of arm’s length prices. Increase threshold
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Luxembourg: Tax authority updates FAQs on CbC reporting
On 18 January 2023, the Luxembourg Tax Authority updated the frequently asked questions (FAQs) on country-by-country (CbC) reporting according to the guidance issued by the OECD in October 2022. The latest updates include the following
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US: IRS invites to comments on CbC report form
As part of its continuing effort to reduce paperwork and respondent burden, on 5 January 2023, the Internal Revenue Service invited the general public and other federal agencies to take this opportunity to comment on proposed and/or continuing
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Iceland: Tax administration announces deadline for 2022 CbC notification
On 2 January 2023, the Icelandic Directorate of Internal Revenue published Notice 1609/2022, announcing the Jan. 31 deadline for submitting country-by-country (CbC) reporting for the fiscal year 2022. The notice contains that the notification must
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South Korea approves budget for 2023
On 23 December 2022, South Korea’s National Assembly approved the budget for 2023 including the tax reform proposal for 2023. Accordingly, South Korea changes the existing tax-related measures including transfer pricing measures. The key tax
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Belarus issues law on various tax amendment
On 4 January 2023, Belarus published Law No. 230-Z in the Official Gazette amending various tax measures. The following are the key amendments to the tax code: From 1 January 2023, the deadline for submitting transfer pricing documentation to
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Israel publishes guidance on CbC reporting
The Israel Tax Authority (ITA) has released guidelines and Technical instructions for the filing of Country-by-Country (CbC) reports. Multi-National Enterprise (MNE) groups with a combined revenue of ILS 3.4 billion and above, starting from the 2022
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Slovak Republic amends TP documentation requirements
The Slovak Ministry of Finance (MoF) has issued new guidelines to determine the content of transfer pricing (TP) documentation, effective for the tax period starting after 31 December 2022. The guidelines reflect an amendment to the income tax
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Argentina: AFIP introduces new mandatory disclosure regime for international transactions
On 27 December 2022, Argentina's federal tax authority (AFIP) released General Resolution No.5306/2022, establishing a new mandatory disclosure regime for certain international transactions. It has replaced the previous mandatory reporting regime
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