North Macedonia proposes amendments to TP reporting
Proposed amendments to the corporate income tax law regarding transfer pricing reporting would become effective from 1 January 2023. The proposed amendments include following changes: the requirement to submit a transfer pricing (TP) report to
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Colombia issues decree on the tax return and TP documentation deadline in 2023
On 16 December 2022, the Colombian Ministry of Finance Published Decree 2487 specifying the deadlines for filing and payment of the tax return (declaration) in 2023 and the deadline for transfer pricing (TP) documentation. Some of the key deadlines
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Germany passed law for implementation of DAC7
On 16 December 2022, Germany passed the DAC7 to modernize tax procedural law. The new law amended Section 90 of the General Tax Code (GTC) and tightened the rules on transfer pricing documentation by allowing tax authorities to request transfer
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Panama declares CbC Reporting deadline
On 30 December 2022, the Resolution 201-9507 was published in Official Gazette No. 29692-A, that extended the deadline for submitting the country-by-country (CbC) report for fiscal year 2021 to 15 January 2023. The CbC report must be submitted
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Brazil issues new transfer pricing legislation to align with OECD transfer pricing guidelines
On 29 December 2022, the outgoing Brazilian President issued draft legislation MP 1.152 to align Brazil’s unique transfer pricing system with the OECD Transfer Pricing Guidelines. The news rule will be compulsory for 2024, for fiscal year 2023,
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Spain releases legislation to implement EU public CbC reporting directive
On 22 December 2022, the Spanish government published the legislation implementing the European Union (EU) Directive (2021/2201) on Public Country-by-Country (CbC) Reporting (CbCR). According to the EU Public CbCR Directive, both EU-based
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Morocco suspends CbC reporting requirement temporarily
On 16 December 2022, the Moroccan tax authority published an announcement, which temporarily suspending the requirement to file a country-by-country (CbC) report for companies that are part of multinational enterprises (MNEs) operating in Morocco
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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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Hungary: MoF publishes draft transfer pricing decree on TP reporting obligation
On 9 December 2022, the Hungarian Ministry of Finance issued a draft transfer pricing decree detailing a new transfer pricing reporting obligation. Accordingly, taxpayers are required to prepare a transfer pricing report on a transaction basis or on
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Slovak Republic implements EU CbC reporting directive
The amendment to the Accounting Act No. 407/2022 implements EU Directive No. 2021/2201 requiring qualifying multinational enterprises (MNEs) doing business in the EU to publicly disclose certain information on a country-by-country (CbC) basis,
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Azerbaijan plans to increase CbC reporting penalty
On 16 November 2022, Azerbaijan submitted a proposal to the Parliament to increase the penalty for failure to submit country-by-country (CbC) reports. Accordingly, penalties for failure to file CbC reports or to comply with other CbC-related
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Poland: President signs the Polish Deal 3.0 including transfer pricing changes
On 21 October 2022, the President of Poland signed the Law of 7 October 2022 amending the Corporate Income Tax Act (referred to as Polish Deal 3.0), including certain transfer pricing changes. One of the most significant changes to transfer pricing
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Singapore: IRAS updates e-tax guide on country-by-country reporting
On 31 October 2022, the Inland Revenue Authority of Singapore (IRAS) published the fourth edition of its e-Tax Guide concerning country-by-country (CbC) reporting. The updated guide includes the following main amendments: Amended to incorporate
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Hungary submits a draft legislation to Parliament on APA and CbCR
On 18 October 2022, Hungarian Ministry of Finance has submitted a draft legislation to the Parliament proposing the amendments of advance pricing arrangements (APAs) and introduction of public CbC reporting. Effective from 1 January 2023, the
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Sweden: Tax Agency Clarifies guideline on the CbC reporting
On 26 October 2022, the Swedish Tax Agency clarified the guideline for the country-by-country (CbC) reporting followed by the OECD. This includes the following clarifications related to guidance provided by OECD: (i) guidance on when positive
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Australia: Budget proposal for FY 2022-23
On 25 October 2022, the Australian Treasurer Jim Chalmers delivered the Federal Budget for fiscal year 2022-23. The key tax measures are as follows: Thin capitalization The Budget amended the thin capitalization rules to limit debt deductions
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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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