Chile extends deadline for transfer pricing returns
On 20 June 2023, the Chilean tax authority (SII) issued Resolution No. 70 that provides an extension of three months to taxpayers who were required to submit their transfer pricing returns between 1 July 2023 and 30 September 2023. The extension
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UK: Second Reading of Spring Finance Bill 2023
On 13 June 2023 the UK government published the Tax Information and Impact Notes for government amendments at the report stage of the Spring Finance Bill 2023. The Bill includes the following measures: Multinational Top-up tax: UK adoption of
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France introduces strict measures to combat international tax fraud
On 5 May 2023, French Minister for public accounts unveils anti-fraud measures targeting international tax and customs activities. Key elements of these measures include lowering the annual turnover threshold that triggers the requirement for
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Malaysia: IRBM publishes transfer pricing rules 2023
On 29 May 2023, the Malaysian Inland Revenue Board of Revenue (IRBM) officially published Order No P.U. (A) 165 (TP Rules 2023) introducing a new transfer pricing documentation process effective from assessment year 2023 onwards. The main changes
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Albania releases a law amending transfer pricing provisions
On 23 May 2023, Vietnam has deposited its instrument of approval for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention). This move makes Vietnam the 81st jurisdiction to
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Germany approves bill on public CbC reporting directive
On 11 May 2023, the lower house of the parliament (Bundestag) approves a bill to implement EU Directive, requiring publicly disclose CbC report for qualifying Multinational Enterprises (MNEs) operating in the EU. The Public Country-by-Country
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UAE: MoF issues decision on TP documentation requirements
On 11 May 2023, the United Arab Emirates (UAE) Ministry of Finance (MoF) issued Ministerial Decision No. 97 of 2023 on the requirements for maintaining transfer pricing (TP) documentation. Federal Decree Law No (47) of 2023 on the Taxation of
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Kenya: Transfer pricing tax measures in Finance Bill 2023
On 28 April 2023, the Cabinet Secretary of the Kenya Ministry of Finance submitted the Finance Bill 2023 (the Bill) to Parliament, which provides the following tax measures related to transfer pricing. The bill proposes to prohibit taxpayers from
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Saudi Arabia: ZATCA approves amendment to the TP Bylaws
On 20 March 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) approved Decision No. 8-2-23 to amend the Transfer Pricing (TP) Bylaws. The approved amendments to the TP Bylaws in Saudi Arabia will expand the scope of the provisions to
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Australia releases draft legislation on public CbC reporting requirement
On 6 April 2023, the Australian Treasury Department issued draft legislation outlining the implementation of public country-by-country (CbC) reporting requirements for specific tax-related information to be disclosed by multinational enterprises
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Lithuania publishes draft law to transpose public CbC reporting
On 7 March 2023, the government of Lithuania issued a draft law to transpose the EU Public Country-by-Country (CbC) Reporting Directive into domestic law. According to the Directive, the upcoming legislation will mandate multinational corporations
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Greece: Public Revenue Authority publishes frequently asked question on CbC Report
On 24 February 2023, the Public Revenue Authority released frequently asked question (FAQ) document in English providing the elaborate description of country-by-country (CbC) reporting, related OECD Country-by-Country reporting guidelines and
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Luxembourg: Government presents a draft bill to the Parliament on public CbC reporting
On 24 February 2023, the Luxembourg government presented Bill no. 8158 to the Parliament to implement public Country-by-Country (CbC) reporting in compliance with Directive (EU) 2021/2101. The bill conforms to the directive and sets the public
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Cyprus: Tax department issues FAQs on new transfer pricing legislation
On 10 February 2023, the Cyprus Tax Department published a set of Frequently Asked Questions (FAQs) aiming to clarify certain provisions of the new transfer pricing rules approved in June 2022 with effect from 1 January 2022, including Local File
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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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