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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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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