Japan: Platform operators are required to remit consumption tax for foreign e-service providers
On 2 February 2024, Japan's Cabinet presented tax reform bills for the year 2024 to the National Diet. Among the proposed changes is the taxation of platform operators, wherein specific operators would be subject to Japanese consumption tax (JCT) as
See MoreSouth Africa: Finance Minister presents the Budget for 2024
On 21 February 2024, Enoch Godongwana, South Africa's Minister of Finance announced the budget 2024. Key tax highlights from the 2024 budget following: Enforcing the global minimum corporate tax: The OECD/G20 Inclusive Framework on Base Erosion
See MoreOECD: Comments Received on Proposed Guidance on Pricing of Lithium
On 26 February 2024 the OECD published the responses received on the proposed guidance to support developing countries in addressing risks of base erosion and profit shifting in pricing lithium. Comments were received from eleven government and
See MoreSingapore: IRAS updates list of jurisdictions under CbC reporting
On 23 February 2024, the Inland Revenue Authority of Singapore (IRAS) revised its Country-by-Country Reporting (CbC) guidance page regarding the jurisdictions eligible for automatic exchange of CbC reports. Papua New Guinea has been included in the
See MoreNigeria: FIRS shifts e-platform for transfer pricing and CbC reporting notifications
Nigeria’s Federal Inland Revenue Service (FIRS), in a notice to taxpayers and the general public, announced the transitioning of the electronic platform for filing transfer pricing returns and country-by-country (CbC) reporting notifications from
See MoreEgypt raises materiality threshold for master file and local file for 2024
On 15 February 2024, Egypt published the Ministerial Decree No. 52 of 2024 in the Official Gazette, providing updated transfer pricing documentation requirements for Egyptian taxpayers. This decree came into effect on 22 February 2024. In this
See MoreGreece proposes new law to implement EU minimum tax rules
On 23 February, 2024, the Greek Ministry of Finance initiated a public consultation on a proposed bill aiming to incorporate the OECD’s Pillar Two Model Rules, as outlined in the EU Minimum Tax Directive. This draft bill is currently open for
See MoreSwitzerland releases Q&A guidance on application of transfer pricing rules
On February 23, 2024, the Swiss Federal Tax Authorities (SFTA) published the Q&A guidance regarding the application of transfer pricing regulations in Switzerland. This guidance clarifies the application of the arm's-length principle and the
See MoreUkraine reports 2023 transfer pricing adjustments results and penalty relief
On 22 February 2024, the State Tax Service of Ukraine published a release about the outcome of the transfer pricing adjustments in 2023. The release mentioned that from 1 August 2023 until the conclusion of martial law in Ukraine, taxpayers can
See MoreFrance extends DAC7 reporting deadline
The execution of EU Directive 2021/514 (DAC7), which mandates the automatic exchange of income information from digital platforms, is facing hurdles and technical issues in various member states. DAC7 establishes 31 January 2024 as the deadline for
See MoreSlovenia enacts adjustments to permanent establishment and interest limitation regulations
On 9 February 2024, Slovenia officially released the Act amending the Corporate Income Tax Act (ZDDPO-2T) in the Official Gazette. The provisions outlined in the legislation encompass: Preventing PE status misuse: New rules limit on strategies
See MoreSpain mandates DAC7 returns from digital platforms by 8 April 2024
On 31 January 2024, Spain published the Royal Decree 117/2024 in the Official State Gazette in which it outlined the implementation of the due diligence procedures and regulations for the compulsory automatic exchange of information among digital
See MoreNorway issues new guidance on transfer pricing reporting requirements for 2024
On 8 February 2024, the Norwegian Tax Administration (NTA) released a guidance regarding the amendments of the transfer pricing disclosures in tax returns for organizations, due by 31 May 2024 for the fiscal year ending in 2023. The guidance
See MoreAustralia holding public consultation on updated public CbC reporting legislation
On 12 February 2024, the Australian Treasury announced it is conducting an additional public consultation regarding implementing new requirements for publishing selected tax information on a Country-by-Country (CbC) basis or public CbC reporting.
See MoreEgypt 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
See MoreMalaysia 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
See MoreBotswana: 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
See MoreBulgaria 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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