Cyprus revises thresholds for transfer pricing documentation
On 1 February 2024, the Cyprus Tax Department released updated thresholds regarding the requirement for taxpayers to prepare a Cyprus Local File for intercompany transactions covered by Section 33 of the Income Tax Law (ITL). These revised
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Belgium implements public country-by-country reporting (CbCR)
On 26 January 2024, Belgium announced the introduction of public country-by-country reporting (CbCR) in the Official Gazette. The new law aligns with the EU Directive 2021/2101 or the EU Public CbCR Directive. On 1 December 2021, the European
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Dominican Republic: DGII enables e-portal for CbC reports submission
On 12 January 2024, the Directorate General of Internal Revenue (DGII) in the Dominican Republic released Notice 01-2024, notifying the availability of the reporting portal for Country-by-Country (CbC) reports. The obligation for Country-by-Country
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Malta issues guidelines for transfer pricing rules
On 19 January 2024, Malta's Commissioner for Revenue published Guidelines in relation to the Transfer Pricing Rules. These guidelines are issued in terms of Article 96(2) of the Income Tax Act (Chapter 123 of the Laws of Malta) and are to be read in
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Italy announces new deadline for transfer pricing documentation
On 12 January 2024, Italy published the Legislative Decree no. 1/2024 in the Official Gazette. The Decree details the simplification and rationalization of certain tax rules, including introducing a new tax calendar. From 2 May 2024, taxpayers
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Ukraine introduces CbC reports filing for the first time
On 11 January 2024, the State Tax Service of Ukraine, in a release announced it has introduced Country-by-Country (CbC) reporting for the parent companies of the international groups of companies for the first time in the country. The CbC reporting
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Qatar extends deadline for CbC reports submission
Qatar’s tax authority announced that it is extending the deadline for Qatar-based companies to submit their country-by-country (CbC) reports for the fiscal year 2022 and CbC notifications for the fiscal year 2023. The new deadline is 31 January
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Poland publishes guidance on transfer pricing, base interest rates, and margin rates
On 29 December 2023, Poland’s Ministry of Finance released the guide on submitting transfer pricing information, which includes: Detailed FAQs related to the obligation to submit transfer pricing information; entity identification
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Ireland publishes new guidance on requesting TP documentation
On 18 December 2023, the Irish Revenue issued eBrief No. 261/23 providing a new Tax and Duty Manual Part 35a-01-05 - Requests for Transfer Pricing (TP) Documentation. This Tax and Duty Manual documents the operational policy of the Transfer
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Belgium enacts law on public CbC reporting
On 21 December 2023, the Belgian Chamber of Representatives passed a legislation for enacting the public Country-by-Country (CbC) reporting as required by Directive (EU) 2021/2101. The Directive mandates that a company is subject to public
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Colombia announces new TP documentation deadlines for 2023 and later
On 22 December 2023, Columbia released Decree 2229, introducing revised deadlines for submitting various forms of transfer pricing documentation. These include the informative declaration, country-by-country (CbC) notification, Local file, Master
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Iceland announces CbC notification deadline for 2023
On 19 December 2023, Iceland published Notice 1525/2023 in the Official Gazette. The notice stipulates that the CbC report notification for the 2023 fiscal year must be submitted within one month from the year's end (by 31 January 2024, for the
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Kazakhstan’s Transfer Pricing Legislative Amendments 2023
Kazakhstan is undergoing a pivotal transformation in its transfer pricing framework, marked by the Majilis' approval of substantial amendments to the existing legislation. The aim is to curb revenue losses, prevent capital outflow, and align with
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Netherlands: Senate passes public CbC reporting bill
The Dutch Senate (upper house of parliament) has passed the bill for implementing public Country-by-Country (CbC) reporting as required by Directive (EU) 2021/2101. The bill facilitates the partial implementation of Council Directive (EU) 2021/2101,
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Algeria announces supplementary finance law for 2023
In November 2023, Algeria published the Supplementary Finance Law for 2023 in the Official Gazette. The key tax measures of the law include: A new transfer pricing declaration obligation has been introduced, requiring taxpayers to submit an
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Ecuador releases updated technical sheet for standardizing the analysis of transfer pricing
On 22 November 2023, the Ecuadorian Tax Authority released a new edition of the technical sheet for the standardization of transfer pricing analysis, effective for fiscal year 2023. This updated document introduces significant changes to filing
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France: Tax authority updates transfer pricing guidelines for SMEs
On 22 November 2023, the French tax authority published an updated transfer pricing guide for small and medium-sized enterprises (SMEs). The guide covers a wide range of topics, including the concept of transfer pricing, the arm's length principle,
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UK: HMRC publishes guidance on transfer pricing records for PEs
The United Kingdom (UK) HRMC has issued guidance on the transfer pricing records requirements for permanent establishments (PEs) in accordance with the amendments made by Finance (No. 2) Act 2023. The Local files and Master files requirements for
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