Egypt preparing draft for new income tax law
Egypt’s Minister of Finance for Tax Policy and Reforms has announced plans to draft a new iteration of the Income Tax Law. The details of the new law has been fully published, but the main proposals of the new law include: A focus on
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Malaysia publishes surcharge FAQs related to transfer pricing adjustments
On 18 January 2024, the Inland Revenue Board of Malaysia (IRBM) published an FAQ list about surcharges for transfer pricing adjustments. The FAQ document is available on the transfer pricing guidance webpage. Under the Finance Act 2020, the tax
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Botswana: Finance Minister presents tax reforms and digitalization measures in budget speech 2024
On 5 February 2024, Mr. Peggy O. Serame, Botswana's Minister of Finance and Economic Development presented the 2024 Budget Speech to the National Assembly. The budget contains a number of important tax measures. The key proposed tax measures are as
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Bulgaria implements public CbC reporting with a higher threshold
Bulgaria has adopted a new law (Law on Amendments and Supplements to the Accountancy Act) that aligns the country with the EU's public Country-by-Country (CbC) reporting requirement (Directive 2021/2101). This means large companies will be required
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Japan submits tax reform bill 2024 to parliament
On 2 February 2024, the Japanese Cabinet submitted the tax reform bill 2024 to parliament. The bill covers various tax measures. Key measures of the bill include: Driving Domestic Growth: The introduction of new tax credit incentives is
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Estonia passes draft law for delaying pillar 2 global minimum tax and public CbC reporting
On 8 February 2024, Estonia's Ministry of Finance, in a release announced that it passed the draft legislation to postpone the implementation of the Pillar 2 global minimum tax until the year 2030. Until that time, the companies that fall within the
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Singapore gazettes order announcing MCAA-CbC as international tax agreement with Kenya and Montserrat
On 1 February 2024, the Singaporean Official Gazette issued Order No. S 69, officially recognizing the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) reports as an international tax compliance
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Greece: AADE extends deadline DAC7 reporting
On 26 January 2024, the Greek Public Revenue Authority (AADE) released Circular No. A.1016, outlining the processes for digital platform operators to submit and automatically exchange information in alignment with DAC7. DAC 7, formally known as
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Russia: MoF issues guidance on expanded tax regimes for transfer pricing
The Russian Ministry of Finance (MoF) issued Guidance Letter No. 03-12-11/1/126454 on 27 December 2023, providing clarification on the application of Order No. 86n from 5 June 2023. This order expanded the list of states with preferential tax
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Singapore: IRAS updates list of jurisdictions under AEOI-CRS
On 1 February 2024, the Inland Revenue Authority of Singapore (IRAS) revised lists of the jurisdictions involved in reportable and participating jurisdictions in the automatic exchange of information (AEOI) regarding financial accounts under the
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Transfer Pricing Brief: February 2024
Australia Special rules for hybrid instruments or entities: The Australian Taxation Office (ATO) published guidance on the hybrid mismatch rules. The guidance explains why hybrid mismatch rules exist, how hybrid mismatch rules work and when
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UK: HMRC publishes transfer pricing guidance on accurate delineation of actual transactions and analysis of risk
On 30 January 2024, the UK HMRC revised its transfer pricing operational guidance by including a new section on the accurate delineation of actual transactions and the analysis of risk. The updated transfer pricing operational guidance is
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Switzerland publishes safe harbor interest rate limits for 2024
On 31 January 2024, the Swiss Federal Tax Administration released two circulars concerning the safe harbor interest rate limits for shareholders and related party financing for 2024. The rates vary based on whether the financing is in Swiss francs
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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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Australia: ATO deliberating on amended interest limitation rules
On 30 January 2024, the Australian Taxation Office (ATO) announced that it is seeking public input and feedback on guidance and advice related to the amendments to the interest deduction limitation rules, also known as thin capitalization rules.
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Australia: ATO issues guidance on hybrid mismatch rules
On 30 January 2024, the Australian Taxation Office (ATO) published guidance on the hybrid mismatch rules. The guidance explains why hybrid mismatch rules exist, how hybrid mismatch rules work and when they should be applied. Australia's hybrid
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Italy: Deadline for initial DAC7 reporting extended
On 30 January 2024, Italy’s Revenue Agency released the Provision (Measure) of 30 January 2024. This legislation is related to the implementation of new regulations regarding the exchange of income information from sellers on digital platforms
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OECD releases ICAP statistics
On 29 January 2024 the OECD released the first aggregated statistics from the Forum on Tax Administration’s International Compliance Assurance Programme (ICAP). ICAP The ICAP is a voluntary risk assessment and assurance program whose
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