Cyprus announces updates to its transfer pricing FAQs
On 28 March 2024, the Cyprus Tax Department released the updated version of its English-language Frequently Asked Questions (FAQs) on transfer pricing. The FAQs present the questions and the corresponding answers as published on the Tax
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Comparative Tax Revenue Effects of Amount A and Digital Service Tax Regimes
As authors of several studies that estimate the tax revenue impact of Amount A for various countries and compare the Amount A impact with revenues from a model digital service tax (DST) regime, we observed certain patterns that hold true for various
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Poland introduces new reporting legislation for digital platform operators (DAC7)
On 22 March 2024, Poland announced a new legislation for the implementation of the Council Directive (EU) 2021/514, known as DAC7. The bill was published on the Government Legislation Centre's website. The legislation introduces several key
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Germany: Bundesrat approves growth opportunities Act
On 22 March 2024, the German upper house of parliament (Bundesrat) declared its endorsement of the Growth Opportunities Act. The lower house of parliament (Bundestag) gave its approval to the Act on 23 February 2024. The bill, initially proposed as
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Ukraine revises form and procedures for county-by-country (CbC) reports
The State Tax Service of Ukraine released updates to the form and procedures for preparing country-by-country reports. Among the main changes to the procedure for filling out the country-by-country report of the international group of companies
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Poland: Parliament passes public CbC reporting legislation
The Polish Parliament has passed a law implementing public Country-by-Country (CbC) reporting in accordance with the requirements of Directive (EU) 2021/2101. This legislation establishes a public reporting threshold for companies with annual
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Colombia: CUP method valid for commodity transactions without quoted prices
The Colombian Tax Authority (DIAN) released Ruling 1118 (Int. 81) of 13 February 2024, which provides clarification of the application of the Comparable Uncontrolled Price (CUP) method for commodity transactions between related parties that do not
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Lithuania sign MCAA to exchange information with respect to income earned on digital platforms
On 4 March 2024, Lithuania signed the multilateral competent authority agreement (MCAA) on the automatic exchange of information on income derived through digital platforms, according to an update published by OECD on 12 March 2024. The DPI-MCAA
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Germany: Federal central tax office issues updated CRS manual
On 5 March 2024, the German Federal Central Tax Office (BZSt) published Newsletter No. 01/2024, addressing updates on the common reporting standard (CRS). Notably, the newsletter announces an extension of the deadline for the non-objection waiver
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Australia: ATO initiates consultation on draft tax determination for hybrid mismatch rules
The Australian Taxation Office (ATO) released the draft Taxation Determination (TD) 2024/D1 - Income tax: hybrid mismatch rules - application of certain aspects of the 'liable entity' and 'hybrid payer' definitions. This draft Determination
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Australia initiates consultation on transfer pricing rules for petroleum resource rent tax
On 18 March 2024, the Australian Treasury announced that it initiated a public consultation on Petroleum Resource Rent Tax transfer pricing regulations. The deadline for receiving comments on the matter is set at 12 April 2024. In the 2023 24
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Estonia: Preliminary bill for public CbC reporting submitted to parliament
On 12 February 2024, a draft bill was introduced to the Estonian Parliament to incorporate the EU Public Country-by-Country (CbC) Reporting Directive into Estonian legislation. The parliament acknowledged there are a limited number of companies that
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Germany: MOF issues updated draft guidance on virtual currency transactions
On 6 March 2024, the German Ministry of Finance (MOF) released revised draft guidance concerning the compliance and documentation criteria for transactions involving virtual currency and tokens. This comes after the issuance of a final decree in May
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Germany: Tax authority publishes list of jurisdictions for automatic exchange of financial account information
On 1 March 2023, the German Federal Central Tax Office released the preliminary list of jurisdictions participating in the exchange of financial account information according to the Common Reporting Standard (CRS) for the year 2024, pertaining to
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Italy announces new corporate tax return deadline
Italy has announced new guidelines and procedures for corporate tax return filings for 2024 regarding the tax year 2023. The main change relates to the revised deadline for filing returns as per the corporate tax (IRES) returns. The new
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Cyprus announces 2024 reference rates for notional interest deduction
On 7 March 2024, the Cyprus Tax Department announced the release of reference rates for 2024 that will be used to calculate the notional interest deduction (NID) on new equity investments. According to regulations, the NID rate is equivalent to the
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Canada: CRA releases new circular on advance pricing arrangements (APAs)
On 22 February 2024, the Canada Revenue Agency (CRA) released the Information Circular 94-4R2 on International Transfer Pricing: Advance Pricing Arrangements (APAs). This circular offers detailed guidance on APAs, focusing on the prerequisites for
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Malta publishes guidance note on pillar 2 global minimum tax
Malta's Commissioner for Revenue released a Guidance Note on the European Union Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups Regulations 2024. This guide clarifies Malta’s partial
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