Australia seeks feedback on amendments to interest limitation rules
On 18 October 2023, the Australian Treasury Department opened a consultation on an exposure draft bill to amend the interest limitation rules. As part of the 2022-23 Budget, an integrity measure was announced to address risks to Australia’s
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US and Israel sign agreement on the exchange of CbC reports
The Internal Revenue Service (IRS) of the United States has released the competent authority arrangement concerning exchanging Country-by-Country (CbC) Reports with Israel. As per the IRS CbC Reporting Jurisdiction Status Table, this arrangement
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Brazil releases normative instruction for its new transfer pricing rules
On 28 September 2023, Brazil published Normative Instruction Nº 2,161 (IN 2,161/23) that governs Brazil’s recently established new transfer pricing law. The new legislation explicitly adopts the arm's length principle into the Brazilian legal
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Slovenia: Tax agency declares CbC reporting deadline
On 10 October 2023, the Slovenian Tax Agency (Financial Administration) declared that country-by-country (CbC) reports for the fiscal year ending on 31 December 2022 , submission is a mandatory requirement by 31 December 2023. Taxpayers must submit
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El Salvador: MoF extends tax amnesty up to 30 September 2023
The Ministry of Finance of El Salvador has introduced a new tax amnesty regime allowing taxpayers to settle their outstanding tax and customs obligations up to 30 September 2023. The El Salvador tax authorities will waive all incurring interest,
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Cyprus announces expected effective date of CbC exchange agreement with the US
On 5 October 2023, the Cyprus Tax Department issued a notice regarding the anticipated implementation date of the agreement for the exchange of Country-by-Country (CbC) reports with the United States alongside the local filing obligations. The
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OECD: Report to the Meeting of G20 Finance Ministers and Central Bank Governors
The OECD Secretary General’s report to the meeting of G20 Finance Ministers and Central Bank Governors covered the following issues: Two-Pillar International Tax Package The Inclusive Framework has now released the text of the Multilateral
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OECD: Multilateral Convention in Relation to Amount A of Pillar One
On 11 October 2023 the OECD’s Inclusive Framework released the finalised text of a multilateral convention in relation to Amount A of Pillar One, to co-ordinate the implementation of the reallocation of taxing rights to market jurisdictions,
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France: FTA publishes update guidelines on DAC6
On 13 September 2023, the French tax authorities (FTA) revised their DAC 6 administrative guidelines in order to provide further clarification on hallmark D.1.b. This particular hallmark relates to the automatic exchange of information and
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Transfer Pricing Brief: October 2023
Armenia Compliance with BEPS standards: On 25 September 2023, Armenia deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI). See the story in
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France submits finance bill for 2024 including Pillar 2 global minimum tax
On 27 September 2023, the government of France presented the 2024 Finance Bill to Parliament. The bill aims to combat inflation, reduce the national debt and promote sustainable development. The Finance Bill includes a provision to implement the
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Latvia publishes law transposing public CbC reporting into domestic law
On 27 September 2023, the Latvian government released the "Information on Revenue and Income Tax Disclosure Law" in the Official Gazette. This law outlines the framework for the adoption of public Country-by-Country (CbC) reporting, aligning Latvia
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Poland releases guidelines relating to cost-plus method in transfer pricing
On 29 September 2023, Poland published formal guidance regarding the application of the cost-plus method to ensure accurate valuation of transactions involving related entities for international tax purposes. The purpose of this guide is to provide
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Armenia deposits its instrument for the ratification of BEPS MLI
On 25 September 2023, Armenia deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI). The Convention will enter into force in relation to Armenia on 1
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Austria: Ministry of Finance releases DAC6 reporting guidelines
On 12 September 2023, the Austrian Ministry of Finance published an updated guidance on the explanation and application of the rules of DAC6 in Austria. This update is a practical guide to understanding EU-MPfG compliance, based on questions and
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OECD: Sixth Annual Peer Review Report on BEPS Action 13
On 25 September 2023 the sixth annual peer review report was issued under BEPS Action 13, looking at the implementation of the minimum standard on country by country (CbC) reporting by jurisdictions at April 2023. The report covers 136 member
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North Macedonia updates TP report submission requirements
On 25 September 2023, North Macedonia officially published amendments to the Profit Tax Law in Official Gazette No.199. According to the amendments, the requirement to submit transfer pricing reports is terminated with effect from 1 January 2024. As
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Ecuador: SRI gazettes resolution amending transfer pricing rules
On 13 September 2023, Ecuador's Internal Revenue Service (SRI) issued Resolution No. NAC-DGERCGC23-00000025, which modifies the transfer pricing rules. The resolution includes following measures: Taxpayers who have conducted transactions with
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