Thailand: TRD updates advance pricing arrangements guidance
In October 2023, Thai Revenue Department (TRD) published updated guidance on advance pricing arrangements (APAs). The guidance on APAs has instructions and requirements for bilateral APAs. The update in the guidance mostly related to the
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UN Adopts Resolution to Set Up a Framework Convention on Tax
On 22 November 2023 the UN general assembly adopted a resolution to commence the process of setting up a framework convention on tax. The framework convention could ensure that the UN is the main body for decision-making on international tax
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Australia: Government releases amended interest limitation rule
On 28 November 2023, the Australian government released the amendments and a supplementary explanatory memorandum to the interest limitation rules within the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and
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Canada announces legislation to implement digital services tax
On 28 November 2023, Ms. Chrystia Freeland, Deputy Prime Minister and Minister of Finance, tabled the Notice of Ways and Means Motion to introduce the Fall Economic Statement Implementation Act, 2023. This legislation, which delivers on key
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Poland extends the deadline for submitting certain TPR forms
On 27 November 2023, the Polish Ministry of Finance issued a regulation extending the deadline for the submission of transfer pricing information forms (TPR-P and TPR-C forms) for individual (personal) and corporate income taxes until 31 January
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Norway to implement global minimum tax
On 24 November 2023, the Norwegian government submitted a draft bill to the parliament to enforce Norway's Pillar 2 global minimum tax rules. On 6 June 2023, the Norwegian Ministry of Finance published a consultation paper on implementing the
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France: Tax authority updates transfer pricing guidelines for SMEs
On 22 November 2023, the French tax authority published an updated transfer pricing guide for small and medium-sized enterprises (SMEs). The guide covers a wide range of topics, including the concept of transfer pricing, the arm's length principle,
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Hungary: Parliament passes pillar two global minimum tax law
On 21 November 2023, the Hungarian Parliament passed legislation to implement the Pillar 2 global minimum tax (GloBE) rules as per the Council Directive (EU) 2022/2523 of 14 December 2022. On 17 October 2023, Hungary’s Ministry of Finance
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Italy implements DAC7 requirements for digital platform operators
The Italian Revenue Agency has declared the release of the Provision of 20 November 2023, outlining the execution of updated reporting and information exchange of information requirements pertaining to income generated by sellers utilizing digital
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Germany: Bundestag approves draft business tax reform bill
On 17 November 2023, the German lower house parliament (Bundestag) passed a bill that seeks to promote economic expansion, stimulate investment, and make the tax system more user-friendly and equitable. Some of the key provisions of the bill
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UK: HMRC publishes guidance on transfer pricing records for PEs
The United Kingdom (UK) HRMC has issued guidance on the transfer pricing records requirements for permanent establishments (PEs) in accordance with the amendments made by Finance (No. 2) Act 2023. The Local files and Master files requirements for
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Kuwait joins the inclusive framework on BEPS
On 15 November 2023, the Organization for Economic Cooperation and Development (OECD) announced that Kuwait joined the inclusive framework on Base Erosion and Profit Shifting (BEPS). Through its membership, Kuwait has also committed to
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Russia: FTS introduce a list of jurisdictions not exchanging CbC reports
The Russian Federal Tax Service (FTS) released a list of jurisdictions that have repeatedly failed to exchange Country-by-Country (CbC) reports electronically with Russia. In cases of systemic exchange failure, a constituent entity within Russia
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Azerbaijan signs MLI to implement tax treaty related BEPS measures
On 20 November 2023, Azerbaijan signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), at a signing ceremony held in Baku. Azerbaijan has become the 102nd jurisdiction to join the BEPS Convention, which
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Greece implements public CbC reporting
On 14 November 2023, Greece published Law No. 5066/2023 in the Official Gazette implementing public Country-by-Country (CbC) reporting in compliance with Directive (EU) 2021/2101. The Law conforms to the directive and sets the public reporting
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Czech Republic approves tax reform measures for FY 2024
The Parliament of the Czech Republic approved the Act on the Consolidation of Public Budgets. Most of the proposed amendments are scheduled to take effect from 1 January 2024. Some of the key tax measures are following: The corporate income tax
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OECD Releases Information and Statistics on Mutual Agreement Procedures
On 14 November 2023 the OECD released the 2022 Mutual Agreement Procedures (MAP) Statistics, covering 133 jurisdictions worldwide. The release of these statistics each year is part of the actions to improve dispute prevention and resolution in line
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Taiwan: MOF reminds taxpayers to submit master file and CbC report by 31st December 2023
On 10 November 2023, Taiwan’s Ministry of Finance (MOF) issued a press release as a reminder to the taxpayers to submit master file and country-by-country (CbC) report. The profit-seeking enterprises that meet the conditions and use the
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