Germany: Ministry of Finance updates transfer pricing guidelines for 2024
The German Ministry of Finance published BMF Letter No. 2024/1078709 on 12 December 2024, updating the guide on transfer pricing for 2024. The new guidelines clarify key aspects of transfer pricing which includes income correction and
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Austria gazettes Pillar Two CbCR Safe Harbour Regulation
Austria’s tax authorities published a decree in the Official Gazette on the temporary CbCR Safe Harbor (CbCR Safe Harbor Regulation) under the Minimum Taxation Act (“MinBestG”) on 5 December 2024. The MinBestG, which came into force on 31
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Australia updates guidance on public CbC reporting
The Australian Taxation Office (ATO) has revised its guidance on the public country-by-country (CbC) reporting regime focusing on public CbC parent registration requirements on 11 December 2024. Australia’s public CbC reporting is a reporting
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Italy announces penalty relief rules for hybrid mismatch rules
Italy's Ministry of Economy and Finance has published the Decree of 6 December 2024 outlining the penalty reliefs rules for violations of Italy's hybrid mismatch rules. The Decree’s penalty relief rules are taken from Legislative Decree No. 209
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Romania clarifies public CbCR reporting rules
Romania’s Ministry of Finance, in a release, outlined the preliminary format for public Country-by-Country (CbC) reporting. This follows after Romania has introduced public country-by-country (CbC) reporting requirements through Order no. 2.048
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Colombia: DIAN sets tax value unit for 2025
The Colombian National Tax and Customs Directorate (DIAN) issued Resolution No. 000193 on 4 December 2024, setting the tax value unit (UVT) at COP 49,799. The UVT is a tool in the Colombian tax system which allows for the annual update of tax
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Australia: Pillar Two minimum tax, PCbC reporting, capital gains withholding laws receive royal assent
Australia’s laws related to the Pillar Two minimum tax, Public Country-by-Country (PCbC) reporting requirements, and capital gains withholding received Royal Assent on 10 December 2024. Pillar Two global minimum tax law The Pillar Two global
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Switzerland updates list of participating jurisdictions for AEOI-CRS
The Swiss State Secretariat for International Finance (SIF) released an updated list of jurisdictions participating in the automatic exchange of information (AEOI) on financial accounts on 5 December 2024. This update aligns with the Common
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US, Norway Competent Authority Arrangement (CAA) enters into force
The US Internal Revenue Service (IRS) has issued Announcement 2024-42 on 9 December 2024 in which it notified taxpayers the US and Norway has entered a competent authority arrangement (CAA) in accordance to the paragraph 2 of Article 27 (mutual
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Nigeria: FIRS publishes guidance on advance pricing agreements
Nigeria’s Federal Inland Revenue Service (FIRS) has released detailed guidelines on Advance Pricing Agreements (APAs), providing a framework for companies to establish transfer pricing agreements with tax authorities in advance. Businesses
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Azerbaijan plans to raise penalties for CBC reporting tax non-compliance
Azerbaijan has proposed changes to the Tax Code on penalties for tax non-compliance and country-by-country (CbC) reporting. The penalty for failing to submit requested documents and information to the tax authorities within 60 days will be
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Taiwan reminds taxpayers of Master File, CbC report submission deadlines for FY2023
Taiwan's Ministry of Finance has issued a reminder to taxpayers about the approaching deadline for submitting the Master File and CbC Report for 2023 on 4 December 2024. The Ministry of Finance states that in order to strengthen tax information
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Switzerland updates MCAA-CbC participation list, adds Armenia, Georgia, Montenegro
An updated the list of participating jurisdictions under the Multilateral Competent Authority Agreement (MCAA) for the exchange of country-by-country (CbC) (Decision No. RO 2024 738) was published in the Swiss Official Gazette on 3 December
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Belgium proposes updates to DAC6, DAC7 rules
Belgium’s government has introduced a draft law proposing updates to the current regulations on the automatic exchange of information (AEOI) and related obligations. The draft legislation also outlines new penalties under DAC6 and DAC7. These
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Netherlands: Amount B will not be introduced for Dutch taxpayers
The Netherlands government has announced, on 4 December 2024, in a decree that it will not be adopting the OECD’s new transfer pricing rules (Amount B). However, it will acknowledge other countries' adoption of the OECD's new transfer pricing
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European Commission issues final rules for CbC reporting directive
The European Commission has published the final version of the Commission Implementing Regulation (EU) 2024/2952 of 29 November 2024 in the Official Journal of the EU on 2 December 2024. This document establishes a common template and electronic
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India extends transfer pricing safe harbor rules to FY 2024-25, updates filing deadline for international transactions
India's Central Board of Direct Taxes (CBDT) has released Notification No. 124/2024 outlining the Income Tax (Tenth Amendment) Rules, 2024 on 29 November 2024. According to the amendment, the transfer pricing safe harbor rules under Rule 10TD of
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OECD: Papua New Guinea signs CRS-MCAA
The Organisation for Economic Co-operation and Development (OECD) has announced that Papua New Guinea has officially signed the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (CRS-MCAA) on 26
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