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
See MoreHungary 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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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
See MoreAustralia 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
See MoreHungary 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
See MoreHungary: 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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