Slovak Republic releases 2023 transfer pricing documentation guidelines
Slovak Republic's Ministry of Finance has issued guidelines (MF/020061/2022-724) outlining the requirements for transfer pricing documentation for 2023. These guidelines categorise transfer pricing documentation into three types: Full-scope
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Ireland: Irish Revenue makes changes to bilateral advance pricing agreement guidelines
On 26 April 2024, the Irish Revenue published eBrief No. 127/24 outlining the updated Tax and Duty Manual Part 35-02-07 Bilateral Advance Pricing Agreement Guidelines. The updated Guidelines take into account international best practices in relation
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Poland enacts public country-by-country (CbC) reporting
On 16 April 2024, Poland’s President has signed into law the legislation enacting the EU public country-by-country (CbC) reporting directive (EU Directive 2021/2101). This law will go into effect 14 days following its official promulgation. The
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Algeria extends deadline for 2023 tax returns and transfer pricing documentation
On 21 April 2024, the Directorate General of Taxes in Algeria announced via a communiqué an extension for the deadline to submit annual tax returns (G4 and G11) and the annual personal income declaration (G1) for the fiscal year 2023. As per the
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Germany gazettes order declaring MCAA-CbC
On 27 March 2024, the German Official Gazette published a regulation that revises the list of jurisdictions involved in the Multilateral Competent Authority Agreement (MCAA) for exchanging country-by-country (CbC) reports. The regulation comes into
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Australia: ATO releases discussion paper on thin capitalization rules for foreign bank branches
On 17 April 2024, the Australian Taxation Office (ATO) published a discussion paper regarding the safe harbor formula for calculating the minimum capital requirements for inward investing deposit-taking institutions (ADIs) under the thin
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Albania: Tax Administration announces CRS reporting deadline
On 15 April 2024, the Albanian Central Tax Administration declared that financial institutions must report for the automatic exchange of financial account information (AEOI) under the common reporting standard (CRS) by the deadline of 30 May 2024.
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Oman: Tax authority issues important notice on CRS reporting and re-registration
On 9 April 2024, the Oman Tax Authority issued an announcement regarding the accessibility of its Automatic Exchange of Information (AEOI) system for submitting Common Reporting Standard (CRS) reports. The Tax Authority has issued a reminder to
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India: CBDT signs record number of 125 advance pricing agreements in FY 2023-24
The Central Board of Direct Taxes (CBDT) has accomplished a landmark achievement by finalizing a record 125 Advance Pricing Agreements (APAs) during the fiscal year 2023-24 with Indian taxpayers. This figure includes 86 Unilateral APAs (UAPAs) and
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France publishes updated list of participating and reportable jurisdictions for CRS purposes
On 28 March 2024, France's Official Journal No. 0074 published the Order of 15 March 2024, which provides a comprehensive and current list of participating and reportable jurisdictions for Common Reporting Standard (CRS) purposes. Common Reporting
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Estonia passes laws for public CbC reporting and partial adoption pillar 2 GloBE rules
On 10 April 2024, Estonia’s parliament passed the Act supplementing the Tax Information Exchange Act, the Taxation Act, and the Income Tax Act (379 SE). This law outlines the requirements for the implementation of public CbC reporting in
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Ireland: Irish Revenue updates tax manuals for outbound payments defensive measures
On 11 April 2024, the Irish Revenue issued eBrief No. 119/24 regarding to the updates on the tax and duty manuals related to the new outbound payments defensive measures. The outbound payments defensive measures are included in the Finance (No.2)
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Poland passes law for implementing DAC7
On 9 April 2024, Poland's Council of Ministers passed a bill to enact new regulations for exchanging information on income generated from sellers on digital platforms, or DAC7. These rules are outlined in Council Directive (EU) 2021/514, which was
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MoF in Ethiopia issues new transfer pricing directive
The Ethiopian Ministry of Finance (MoF) released Directive No. 981/2024 (referred to as "The Directive"), introducing new transfer pricing regulations, concerning the pricing of international and domestic transactions between related persons whose
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Ireland: Irish Revenue publishes guidance on outbound payment measures
On 25 March 2024, the Irish Revenue released eBrief No. 096/24 outlining new guidance on Outbound payments defensive measures. This latest guidance has been issued as part of the Finance (No.2) Act 2023. The Finance (No.2) Act 2023 inserted Chapter
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Czech Republic announces draft legislation for enacting DAC8
On 25 March 2024, the Czech Republic government announced the release of the Draft Bill amending the Act on International Cooperation in Tax Administration and Other Related Acts to implement Council Directive (EU) 2023/2226 of 17 October 2023. This
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Hungary releases 2024 audit plan with targets transfer pricing
Hungary's National Tax and Customs Administration (NAV) has released its audit strategy for the 2024 calendar year, highlighting transfer pricing as its key area of focus among other sectors. The new transfer pricing reporting obligation introduced
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Germany: Parliament approves law for growth, investment, and tax simplification
The Bundesrat, upper chamber of the German Parliament, gave its approval to the compromise proposal for the "Act aimed at Enhancing Growth Opportunities, Investment, and Innovation, while Simultaneously Simplifying Taxation and Ensuring Fairness" on
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