Romania gazettes public CbC reporting directive
On 7 September 2022, the Romanian Official Gazette published the regulations to implement the EU Public country-by-country (CbC) Reporting Directive. The Directive requires qualifying multinational companies operating business in the EU to publicly
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Belgium notifies TP penalties first time
The Belgian tax authorities have sent out the first penalty notifications for noncompliance to submit transfer pricing (TP) forms. Generally, TP documentation requirements is mandatory for Belgian entities exceeding the respective thresholds and
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Germany: CJEU has issued a decision on sanctions for non-compliance with TP documentation requirements
On 13 October 2022, the Court of Justice of the European Union (CJEU) ruled in case: C-431/21 on sanctions for non-compliance with transfer pricing (TP) documentation requirements. Under German law, there is a rebuttable presumption that the
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Germany: Government publishes a draft bill for public CbC reporting
On 30 September 2022, the German Federal Ministry of Justice published draft legislation for the implementation of EU public country-by-country (CbC) reporting Directive 2021/2101 as regards the disclosure of income tax information by certain
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Belgium declares deadline for filing Local file forms
Belgian tax authority has declared the deadline for filing Local file forms (275LF) is 17 October 2022. The submission of a Local file is required for Belgian companies and permanent establishments (PEs) that meet at least one of three
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Australia updates local file and master file guidelines for 2022
On 9 August 2022, the Australian Taxation Office (ATO) updated guidance on the Local and Master file for 2022 along with instructions. The guidance applies to reporting periods beginning on or after 1 January 2021. The local file must be
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Hungary gazettes the 2023 Budget bill including transfer pricing changes
On 27 July 2022, the Hungarian Official Gazette published the Budget Bill (Law XXIV of 2022) providing for amendments to the Hungarian transfer pricing regulations. The law was passed by the parliament on 19 July 2022. The law includes the following
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Hungary: Parliament adopts a bill imposing additional requirement for TPD
On 19 July 2022, the Hungarian Parliament passed a bill introducing important changes to the transfer pricing rules. The law introduces a significant additional reporting requirement for intra-group transactions and requires transfer pricing
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UK plans to introduce three-tiered documentation requirements
On 20 July 2022, the UK Government published draft legislation as part of the Finance Bill 2022-23 which will make it a requirement for large multinational businesses operating in the UK to keep and retain transfer pricing (TP) documentation in a
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Israel introduces three-tiered TP documentation requirements
On 30 June 2022, the Israeli Parliament passed legislation to amend Section 85A of the Income Tax Ordinance (ITO) and its regulations, by introducing three-tiered transfer pricing documentation requirements of BEPS Action 13. The legislation
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Kenya: Major changes in transfer pricing rules under Finance Act 2022
On 8 July 2022, the Kenyan Finance Act 2022 was gazetted which was signed into law by the President on 21 June 2022. The law introduced a number of changes to the transfer pricing regulatory framework in Kenya that will have far-reaching
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Saudi Arabia issues draft Transfer Pricing Bylaws for public consultation
On 4 July 2022, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued a draft of Transfer Pricing (TP) Bylaws and invited public consultation. The public consultation period is open until 30 July 2022. The final Transfer Pricing Bylaws
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Portugal extends the deadline to submit the TP file
On 6 July 2022, the government announced that it would extend the transfer pricing (TP) deadlines for preparation and/or submission to the tax authority. The deadline is extended from 15 July to 15 September 2022 without any accruals or
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Cyprus: Parliament adopts new transfer pricing legislation
On 30 June 2022, the Cyprus House of Representatives enacted detailed transfer pricing legislation amending the Cyprus Income Tax Law (ITL) and the issuance of Regulations. The amendment includes the new TP documentation requirements and a framework
See MoreKenya: President gives assent to the finance act 2022
On 21 June 2022, Kenya’s President has given his assent to the Finance Act 2022 which was presented to the Parliament on 13 April 2022. The act contains following tax measures mostly take effect on 1 July 2022. The Bill proposed to introduce
See MoreDominican Republic: DGII publishes clarifications on CbC Reporting for MNE
On 22 June 2022, the Directorate General of Internal Revenue (DGII) published a Notice (No. 18-22) clarifying Country-by-Country Reporting (CbC) for Multinational Enterprises (MNEs). The notice includes the following procedures: Submit CbC
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OECD: Tax Administration 2022
On 23 June 2022 the OECD’s Forum on Tax Administration (FTA) issued Tax Administration 2022, which is the tenth edition of the report. The report sets out internationally comparative data on various features of tax systems and tax
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Qatar: Tax authority updates master file and local file submission deadline
On 8 June 2022, the General Tax Authority (GTA) of Qatar issued Decision No. 10 of 2022 that amends certain provisions in Decision No. 4 of 2020 to clarify that the deadline for filing the transfer pricing Master File (MF) and Local File (LF) is 60
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