Australia: ATO updates guidelines on central management and control test of residency
The Australian Taxation Office (ATO) has released updated guidelines that give foreign companies greater certainty about the compliance under the central management and control test. For better clarification to foreign companies regarding their
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Singapore Gazettes Order Declaring MCAA-CbC
On 6 November 2023, the Singaporean Official Gazette issued Order No. S 714 confirming the effective dates for the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country Reports (CbC) with specific jurisdictions.
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Malta: CfTC launches DAC7 registration portal
On 9 November 2023, the Commissioner for Tax and Customs (CfTC) of Malta launched the registration portal on the reporting obligations of Digital Platform Operators imposed by DAC7 (Council Directive (EU) 2021/514). A Platform Operator must
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South Africa: SARS issues updated guide on taxation
On 1 November 2023, the South African Revenue Service (SARS) issued an updated guide on taxation. This guide providing a high-level overview of the most significant tax legislation administered in South Africa by the Commissioner for the South
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OECD: Consultation on Transfer Pricing Issues Relating to Lithium
On 6 November 2023 the OECD and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) released for public consultation a draft toolkit with the title Determining the Price of Minerals: Application to Lithium. The
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OECD: Guidance on Transfer Pricing Issues for Bauxite
Following the completion of a previous consultation, on 6 November 2023 the OECD published a toolkit with the title Determining the price of minerals: A Transfer Pricing Framework – Schedule A: Bauxite. This toolkit follows on from the publication
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OECD: Practice Note on Transfer Pricing for Minerals
On 6 November 2023 the OECD published the final version of a practice note with the title Determining the price of minerals: A Transfer Pricing Framework. The practice note has been developed after consultation with interested parties with the aim
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Philippines joins the inclusive framework to combat tax avoidance and implement BEPS standards
On 8 November 2023, the Philippines joined as a member of the Organisation for Economic Cooperation and Development (OECD)/G20 Inclusive Framework on Base-Erosion and Profit Shifting (BEPS) Inclusive Framework. The Inclusive Framework on BEPS is
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Australia increases interest rate for simplified transfer pricing record-keeping options for loans
On 8 November 2023, the Australian Taxation Office (ATO) released an updated version of practice compliance guideline on simplified transfer pricing record-keeping options (PCG 2017/2). The updates outline the safe harbor interest rate for the
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Ireland: Revenue publishes registration guidelines for platform operators under DAC7
On 6 November 2023, the Irish Revenue issued eBrief No. 235/23, which provides registration Guidelines for platform operators for the exchange of information on income generated through digital platforms (DAC7). With effect from 1 January 2024,
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US: IRS introduces new measures to ensure tax payment by major corporations
On 20 October 2023, the US IRS announced new initiatives funded by the Inflation Reduction Act. These initiatives. These new initiatives aim to ensure that large corporations pay their outstanding taxes and intensify IRS efforts in pursuing
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Hungary approves new CbC exchange agreement with the US
On 2 November 2023, Hungary formally approved signing a new Country-by-Country (CbC) exchange agreement with the United States. The agreement—Decree No. 1482/2023—was published in the Official Gazette. This follows the previous CbC exchange
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Cyprus consents to the Pillar Two QDMTT and the transitional UTPR Safe Harbours
On 30 October 2023, the government of Cyprus released a press release announcing its consent to the design and application of the transitional Undertaxed Profits Rule (UTPR) Safe Harbour and the permanent Qualified Domestic Minimum Top-up Tax
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Albania introduces new income tax framework, bringing significant changes from 2024
On 20 September 2023, Albania released Income Tax Instruction No. 26 in the Official Gazette, laying the groundwork for the enforcement of Income Tax Law No. 29/2023. The Income Tax Law No. 8438/1998 was repealed and replaced by Law No. 29/2023,
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Hungary: MOF introduces draft legislation on BEPS 2.0 pillar two to parliament
On 31 October 2023, the Hungarian Ministry of Finance presented the draft legislation to the parliament regarding the implementation of EU Directive 2022/2523 on the global minimum tax. As previously reported, the Ministry of Finance released
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Saudi Arabia: ZATCA releases drafts of new income tax and tax procedural laws for public consultation
On 25 October 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued drafts of a new Income Tax Law and Zakat and Tax Procedures Law for public consultation. The public consultation period for comments on the drafts is open until 25
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Italy: Revenue agency issues draft guidelines on investment management transfer pricing
On 20 October 2023, the Italian Revenue Agency issued the draft transfer pricing guidelines for implementing the Investment management exemption regime (IME). The draft was in public consultation until 3 November 2023. The IME was introduced by
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Transfer Pricing Brief: November 2023
Australia Documentation: The Australian Tax Office (ATO) has announced that taxpayers with CbCR obligations for the year ending 31 December 2022 will now have until 31 January 2024 to submit their reports. This extension applies to the CbC
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