Belgium: Constitutional court revokes several federal and regional DAC6 legislation
On January 11, 2024, the Belgian Constitutional Court released a statement regarding four judgments related to legislation passed by the Federal government, the Walloon region, Brussels, and the French Community. These judgments pertain to the
See More
Transfer Pricing Brief: January 2024
Algeria Transfer pricing information return: Algeria published the Supplementary Finance Law for 2023 in the Official Gazette. A new transfer pricing declaration obligation has been introduced, requiring taxpayers to submit an online transfer
See More
Albanian official Gazette publishes revised AEOI jurisdictions list
On 5 January 2024, Albania's Official Gazette announced Decision No. 817, a major update to its automatic exchange of financial account information (AEOI) program. This decision revamps the lists of participating and reportable jurisdictions,
See More
France enacts 2024 finance law with global minimum tax rules
On 30 December 2023, France released its Finance Law for 2024 (Law no. 2023-1322) in the Official Gazette, along with the Constitutional Court's review, affirming the constitutionality of key tax measures. A major highlight is the implementation of
See More
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
See More
Colombia issues tax return filing deadlines for year 2024 and beyond
On 22 December 2023, Colombia's Ministry of Finance published Decree No. 2229 of 22 December 2023, outlining the deadlines for filing tax returns and payments for the year 2024 and subsequent years. The main deadlines for tax returns and payments
See More
Poland announces base interest rates for related party debt for 2024
On 3 January 2024, Poland’s tax authority published a release related to a notice on the base interest rates and margins for the safe harbor simplification for loan, credit, or bond transactions between related parties in 2024. The safe harbor
See More
India: CBDT updates safe harbor rules for intragroup financing
On 19 December 2023, the Central Board of Direct Taxes (CBDT) in India announced significant changes to the safe harbor rules for intragroup financing arrangements. These updates, outlined in Notification No. 104/2023, will take effect on 1 April
See More
Netherlands publishes DAC7 FAQs
On January 1, 2024, the Netherlands’ tax authorities released a series of frequently asked questions (FAQs) to clarify the Netherlands’ reporting obligations and procedures under DAC7. The FAQs provide details regarding specific key terms,
See More
South Korea approves 2024 tax reform bill and postpones undertaxed profits rule
On December 31, 2023, South Korea implemented the 2024 Tax Reform Bill (the 2024 Tax Reform) after approval from Korea's National Assembly on 21 December 2023. The 2024 Tax Reform will take effect for fiscal years starting on or after 1 January 1,
See More
Indonesia releases revised guidelines for transfer pricing
On 29 December 2023, Indonesia’s Minister of Finance (MoF) released the revised transfer pricing guidelines Regulation No. 172 of 2023 (PMK-172). The updated and consolidated transfer pricing regulations in various chapters, such as: General
See More
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
See More
US: IRS evaluating group membership to fix arm’s length interest rate
On 29 December 2023, the Office of Chief Counsel Memorandum announced that the IRS is considering group membership to determine the arm's length interest rate chargeable for intragroup loans and make a section 482 adjustment. The memorandum provides
See More
Netherlands updates low-tax and non-cooperative jurisdictions list for 2024
On 29 December 2023, the Dutch State Secretary of Finance published an end-of-year regulation in the Official Gazette. The regulation has been updated to revise the lists of low-tax and non-cooperative jurisdictions for tax purposes. Effective
See More
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
See More
Germany: Bundesrat approves secondary credit market promotion Act
On 14 December 2023, upper house of parliament (Bundesrat) granted approval to the Secondary Credit Market Promotion Act. The Act had already received approval from the German Bundestag (lower house of parliament) on 13 December 2023 and is
See More
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
See More
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
See More