Malta: CFR updates guidelines on the reporting obligations of DAC7
On 31 August 2023, the Maltese Commissioner for Revenue (CFR) updated guidelines in relation to the reporting obligations of Digital Platform Operators (DAC7). The DAC7 requirements come into effect on 1 January 2023 into Maltese domestic law. The
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Luxembourg implements public CbC reporting
On 22 August 2023, Luxembourg published Law of 15 August 2023 in the Official Gazette implementing public Country-by-Country (CbC) reporting in compliance with Directive (EU) 2021/2101. The Law conforms to the directive and sets the public
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India: CBDT extends transfer pricing Safe Harbor Rules
On 9 August 2023, the Central Board of Direct Taxes (CBDT) issued a Notification No. 58/2023, to extend the applicability of the transfer pricing safe harbor rules. The extension applies for the financial year 2022-23 and 2023-24 assessment years.
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Anguilla suspends exchange of tax information with Russia and Belarus
On 21 August 2023, the Government of Anguilla announced the suspension of exchanges and the sharing of tax information with Russia and Belarus in solidarity with the United Kingdom (UK) Government. Tax information is exchanged as part of a
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Portugal implements CbC reporting requirements
On 23 August 2023, the Portuguese government published Decree-Law No. 73/2023 in the Official Gazette, which establishes the requirements for public country-by-country (CbC) reporting by multinational enterprises (MNEs). The new rules on public
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UK updates transfer pricing documentation requirements
The United Kingdom (UK) has published the Transfer Pricing Records Regulations 2023, which updated transfer pricing documentation requirements by introducing Local file and Master file requirements. The UK has officially updated its transfer
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IMF: International Tax Spillovers and Tangible Investments
On 4 August 2023 an IMF working paper was published with the title International Tax Spillovers and Tangible Investments, with Implications for the Global Minimum Tax, authored by Michael Keen, Li Liu and Hayley Pallan. The paper assembles new data
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UN: Report of the Secretary General on Promoting Inclusive Tax Cooperation
An advance unedited report released by the UN Secretary General on 8 August 2023 considered the Promotion of inclusive and effective international tax cooperation at the United Nations. A final version of the report is to be released in time for the
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UK: HMRC announces new reporting regulations for digital platform operators (DAC7)
On 20 July 2023, the United Kingdom’s HMRC issued a policy paper outlining a comprehensive plan to establish reporting regulations for digital platform operators operating in the United Kingdom (UK). This initiative, which aligns with the OECD
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Ukraine ensures technical capacity for information exchange on CRS and CbCR
On 17 August 2023, Ukraine announced that the development of software for the State Tax Service of Ukraine has been completed, which will ensure the international automatic exchange of information under the Common Reporting Standard (CRS) and the
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Israel releases Guidance on MAP and APA procedures
On 17 August 2023, the Israel Tax Authority (ITA) released Tax Circular No. 1/2023, which provides guidance for mutual agreement procedure (MAP), and bilateral advance pricing agreement (APA) requests. The new circular replaces the guidance of
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Canada updates electronic filing requirements for business entities
On 16 August 2023, the Canada Revenue Agency (CRA) announced that businesses filing six or more information returns must file them electronically to avoid penalties. Recent legislation has amended mandatory electronic filing thresholds.
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Canada releases revised draft DST Act for public comments
On 4 August 2023, the Department of Finance Canada published a revised draft of the Digital Services Tax (DST) Act for public consultation. These legislative proposals would implement the Digital Services Tax Act. The Act would impose a tax
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France updates list of exempted countries for CbC report local filing requirements
On 13 August 2023, Government published the Decree which amends the Order 6 July 2017 pursuant to II of Article 223 quinquies C of the General Tax Code. The new Decree updates the the list of country exemption from local filing Country-by-Country
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Paraguay upgrades transfer pricing documentation process
On 20 July 2023, the tax authority of Paraguay (SET) issued General Resolution No. 134 of 18 July 2023, that introduces an exceptional mechanism for the submission of the technical transfer pricing study (Estudio Técnico de Precios de Transferencia
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South Korea: MOEF announce tax reform proposal for 2023
On 27 July 2023, South Korea’s Ministry of Economy and Finance (MOEF) announced the tax reform proposal for 2023. The tax reform proposal includes changes in the Korean Pillar two global minimum tax rules and transfer pricing compliance
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Netherlands: House of Representatives adopts legislation for public CbC Reporting
On 6 July 2023, the Dutch House of Representatives passed legislation aimed at implementing the Public Country-by-Country (CbC) Reporting Directive. This move highlights the Netherlands' commitment to transparency and aligns with international
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South Africa publishes a draft legislation to implement APA program
On 31 July 2023, the National Treasury of South Africa proposes a draft legislation to implement advance pricing agreement (APA) program. An APA program offers taxpayers an enhanced level of assurance when engaging in significant international
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