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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Singapore: IRAS updates list of jurisdictions participating under MCAA-CbC
On 30 October 2023, the Inland Revenue Authority of Singapore (IRAS) updated the list of jurisdictions participating under the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports. Under the list:
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Kuwait set to implement corporate income tax for all entities
According to a recent report, the Kuwaiti government is planning to broaden the scope of corporate income tax to include all entities in Kuwait at a rate of 15%, except for small enterprises. Currently, the CIT is 15% for foreign companies carrying
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Malta pushes back initial DAC7 registration deadline
On 27 October 2023, the Maltese Commissioner for Tax and Customs notified that Version 1.2 of the updated guidelines on the reporting obligations of Digital Platform Operators imposed by DAC7 (Council Directive (EU) 2021/514), has been issued
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UAE: FTA releases transfer pricing guide
On 23 October 2023, the Federal Tax Authority (FTA) of the United Arab Emirates (UAE) released the Transfer Pricing Guide. This guide is designed to provide general guidance on the Transfer Pricing regime in the UAE with a view to making the
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Ireland: Revenue updates guidance for platform operators under DAC7
On 23 October 2023, the Irish Revenue issued eBrief No. 231/23, which provides updated guidance for platform operators for the exchange of information on income generated through digital platforms (DAC7). The provisions relating to the reporting
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Poland: MoF extends transfer pricing reporting deadline for 2022
On 27 October 2023, the Ministry of Finance in Poland decided that it planned to extend the deadline for submitting transfer pricing reporting forms (TPR-P and TPR-C) by 3 months, from 30 November 2023 to 29 February 2024. This extension is due to
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Australia extends deadline for submitting CbC reports, Master file & Local file
The Australian Tax Office (ATO) has announced that taxpayers with country-by-country (CbC) reporting 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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UN Tax Committee considers transfer pricing and treaty issues
The 27th session of the UN Committee of Experts on International Cooperation in Tax Matters took place from 17 to 20 October 2023. Subcommittees dealing with various areas of taxation presented updates to the Tax Committee on their
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Slovenia: MoF issues a draft bill to amend the corporate income tax law
On 17 October 2023, the Slovenian Ministry of Finance (MoF) issued a draft bill to amend the corporate income tax law. Once adopted by the Slovenian parliament the amendments will apply from 1 January 2024. The following amendments are
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Uganda releases public notice on implementation of DST
On 20 October 2023, the Uganda Revenue Authority (URA) released a public notice on the implementation of digital service tax (DST). Accordingly, URA informs the general public and non-resident persons providing digital services that the Income Tax
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Greece issues a draft bill on CbC reporting requirements for public consultation
On 19 October 2023, the Greek Ministry of Development issued a draft bill for consultation that provides for the introduction of public Country-by-Country (CbC) reporting in compliance with Directive (EU) 2021/2101. The bill conforms to the
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Egypt releases explanatory instructions on transfer pricing reporting obligations
On 19 September 2023, the Egyptian Tax Authority issued Explanatory Instruction No. 78 introducing mandatory transfer pricing reporting obligations for related party transactions. Accordingly, the Tax Authority has set deadlines for submitting
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Ukraine proposes to temporarily double the corporate income tax rate for banks
On 19 October 2023, the Ukrainian Parliament (Verkhovna Rada) passed Draft Law 9656-d in the first reading. Accordingly, Ukraine proposes to temporarily double the corporate income tax rate from 18% to 36% for banks for tax periods starting from 1
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Poland introduces new electronic templates to report transfer pricing
On 17 October 2023, the Polish Ministry of Finance released new electronic templates for transfer pricing reporting on its website. These templates include: Personal Income Tax Transfer Pricing Report - TPR-P(5) Corporate Income Tax
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Belgium releases FAQ on DAC7 obligations of digital platform operators
The Ministry of Finance in Belgium has recently released a Frequently Asked Questions (FAQ) addressing the obligations of digital platform operators imposed by DAC7 (Council Directive (EU) 2021/514). Under DAC7 rule, the digital platform
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Belgium approves draft law on public CbC reporting
On 13 October 2023, the Belgian Council of Ministers passed the preliminary draft law for transposing the EU public country-by-country (CbC) reporting directive (2021/2101). According to the new public (CbC) rules, groups with consolidated
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Chile declares revised tax return deadlines for 2024
On 4 October 2023, the Chilean federal tax agency published Resolution No. 116 with revised filing deadlines of different forms for the 2024 tax year. The deadlines of forms are as follows: March 1: Forms 1811, 1822, 1834, 1891, 1900, 1902,
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