Australia conducting performance audit on TP management
The Australian National Audit Office (ANAO) is conducting a performance audit to evaluate the efficiency of the Australian Taxation Office's (ATO) transfer pricing (TP) management concerning loans between related parties. The ANAO proposes to
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Georgia adopts rules on Mutual Agreement Procedures (MAP)
The Ministry of Finance of Georgia recently published Decree No. 258 of July 2023, which approves the rules for the Mutual Agreement Procedures (MAP) under the Tax Treaties of Georgia or the provisions of the BEPS MLI. The rules encompass various
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OECD: Mitigating the Risks of Illicit Financial Flows in Oil Commodity Trading
On 8 August 2023 the OECD issued policy guidance for policymakers and practitioners on managing the problem of Illicit Financial Flows (IFFs) in oil commodity trading. The Policy Guidance on Mitigating the Risks of Illicit Financial Flows in Oil
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Transfer Pricing Brief: August 2023
Cyprus Local file: On 6 July 2023, the Cyprus Tax Department released a new circular (6/2023) entitled “Simplification measures for persons exempt from the obligation to maintain a Cyprus local file”. The Circular clarifies that persons
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Spain: National Court issues rule on TP adjustment using median of arm’s length range
On 29 July 2023, the Spanish National Court issued a decision that provided clarification on the range of arm's length pricing adjustments applicable. In this case, Ferroli Spain, a Spanish manufacturer specializing in non-electric stoves,
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Serbia amends the law to ratify BEPS MLI
On 27 July 2023, Serbia published in the Official Gazette Decree No. 78 of July 2023, approving amendments to the Law on Ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent Base Erosion and
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Pakistan: FBR issues circular on finance Act changes
On 26 July 2023, the Federal Board of Revenue in Pakistan (FBR) issued Circular No. 2 of 2023, providing an explanation of the income tax amendments introduced through the Finance Act of 2023. The circular elaborates on the following
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Vietnam publishes notice regarding entry into force for BEPS MLI
On 28 July 2023, Vietnam gazetted the “Notice No. 12/2023/TB-LPQT of 21 June 2023” regarding entry into force for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). The MLI will be entered into force on 1
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Papua New Guinea signs multilateral competent authority agreement on exchange of CbC reports
On 26 July 2023, the OECD published their updated list of signatories for the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country Reports (CbCR), showing that Papua New Guinea joined the agreement on 14 March
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Singapore updates list of jurisdictions under MCAA-CbC
On 20 July 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. Aruba has been
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Egypt publishes income tax amendment law
On 15 June 2023, the Egyptian Tax Authority published Law No. 30 of 2023 in the Official Gazette amending some provisions of the Income Tax Law No. 91 of 2005. The Law entered into force on 16 June 2023. The key amendments to the Income Tax Law are
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Germany released new draft guidance on anti-hybrid rules
On 14 July 2023, the German Ministry of Finance has released a draft decree outlining the application of the country's anti-hybrid rules, established in 2021 under the European Union (EU) Anti-Tax Avoidance Directive (ATAD) implementation Law. These
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Ireland: Revenue issues guidelines on EU tax dispute resolution mechanisms
On 17 July 2023, the Irish Revenue issued eBrief No. 165/23 on European Union (EU) tax dispute resolution mechanisms. Accordingly, Tax and Duty Manual Part 35-02-10 - Guidelines on the European Union (Tax Dispute Resolution Mechanisms) Regulations
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Luxembourg: Parliament adopts bill on public CbC reporting
On 19 July 2023, the Luxembourg Parliament adopted Bill no. 8158 to implement public Country-by-Country (CbC) reporting in compliance with Directive (EU) 2021/2101. The bill conforms to the directive and sets the public reporting threshold at an
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OECD: Subject to Tax Rule
On 17 July 2023 the OECD published details of the subject to tax rule (STTR) developed by the Inclusive Framework on BEPS as part of Pillar Two of the two-pillar proposals on international tax. The STTR gives jurisdictions the right to “tax
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Morocco delays approval of Multilateral Automatic Exchange of Information Agreements
In a recent session, held on 20 July 2023, the Moroccan House of Representatives made the decision to postpone the approval of the Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (CbC MCAA), as well as
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OECD: Outcome Statement on the Two Pillar Solution
On 11 July 2023 an Outcome Statement on the two-pillar international tax solution was approved by 138 member jurisdictions of the Inclusive Framework on base erosion and profit shifting. The Outcome Statement summarises the package of deliverables
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OECD: Consultation on Amount B of Pillar One
On 17 July 2023 the Inclusive Framework issued a consultation document asking for stakeholder input on Amount B under Pillar One. Comments are invited by 1 September 2023. Amount B applies to baseline marketing and distribution activities, which
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