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
See MoreUkraine clarifies transfer pricing requirements under martial law
On 2 June 2022, the Ukrainian State Tax Service (STS) has published a notification that clarifies transfer pricing requirements under martial law conditions in Ukraine, taking into account of COVID-19 situation. Transfer pricing
See MorePoland: MoF publishes draft decree changing the TP reports
On 25 April 2022, the Polish Ministry of Finance published a draft decree to change the scope of data and information to be disclosed via transfer pricing reports. The changes introduced by the draft decree include limiting the scope of transfer
See MoreDenmark introduces new filing requirements for TP documentation
Recently, the Danish Ministry of Finance introduced an obligation to file a transfer pricing documentation (TPD) with the Danish Tax Authorities on an annual basis. For the financial years beginning on or after 1 January 2021, the new law requires
See MoreKenya: Transfer pricing measures in Finance Bill 2022
On 12 April 2022, the Finance Bill 2022 was presented in the National Assembly of Kenya, which provides following tax measures related to transfer pricing. The Bill aims to amend Section 18(A) of the ITA to include transactions between residents
See MoreZambia: Government implements budget tax changes for 2022
Recently, the Zambian Government has published Practice Note No. 1/2022 which provides an overview of the various 2022 tax changes implemented through the Budget 2022 Amendment Acts. The most important changes are summarized below: Corporate
See MoreParaguay issues resolution on TP reporting requirements
On 7 April 2022, the tax authority of Paraguay has issued General Resolution No. 115/2022, which provides detailed rules on the preparation and submission of the transfer pricing (TP) reporting requirements as per Law No. 6380/2019 and
See MoreOman publishes guidelines to clarify CbC reporting obligations
In March, the Tax Authority published guidance clarifying the country-by-country (CbC) reporting requirements of multinational corporations (MNEs) operating in Oman. The guide provides a general overview of the CbC reporting requirements as part of
See MoreCroatia: Tax Administration declares CbC notification deadline
On 11 April 2022, the Tax Administration declared that the notification deadline for submitting Country-by-Country (CbC) report until 2 May 2022. This deadline applies for multinational entities
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