OECD Tax Talk Outlines Progress on Two Pillar Proposals
An OECD Tax Talk held on 19 July 2023 summarised recent developments on the two-pillar international tax proposals. Pillar One – MLC The implementation of Pillar One will require a multilateral convention (MLC) to ensure that the
See More
Romania provides guidelines on public CbC reporting obligations
On 21 June 2023, the Romanian Government issued guidance to implement of the EU Public Country-by-Country (CbC) reporting Directive in the Official Gazette. On 1 September 2022, Romania became one of the first European Union (EU) Member States to
See More
Nigeria: FIRS extends the deadline for filing CIT returns for 2023
On 10 July 2023, the Executive Chairman of the FIRS, Muhammad Nami, issued a Public Notice extending the deadline for filing companies’ income tax returns and paying the related tax liabilities. The new deadline is set for 31 August 2023,
See More
Turkey implements corporate income tax rate hike
On 15 July 2023, the Turkish Revenue Administration published Law No. 7456 in the Official Gazette. Accordingly, the general corporate income tax rate has been raised from 20% to 25%. The corporate income tax rate for companies operating in the
See More
Uganda: Parliament approves digital service tax on non-resident digital service providers
On 11 July 2023, the Ugandan Parliament approved Income Tax (Amendment) Bill 2023, which introduces a 5% digital service tax (DST) on every non-resident deriving income from providing digital services in Uganda. After President's approval, the law
See More
Cyprus: Tax Department issues circular on back-to-back financing transactions
On 7 July 2023, the Cyprus Tax Authority released Circular 7/2023, focusing on transfer pricing for intra-group back-to-back financing transactions. The Circular specifies that starting from the tax year 2023, the Comparable Uncontrolled Price (CUP)
See More
Lithuania updates definition of reverse hybrid entities to comply with ATAD2
Lithuania has amended its definition of a "reverse hybrid entity" to comply with the EU Anti-Tax Avoidance Directive (ATAD2). Previously, a Lithuanian entity was considered a reverse hybrid if it was owned by a tax resident of a foreign country, and
See More
Cyprus: Tax department issues transfer pricing simplification measures
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 provides guidance for persons exempt from the
See More
Kenya: Tax measures in finance act 2023
On 3 July 2023, the Kenya Revenue Authority published the Finance Act 2023, following its presidential assent on 26 June 2023. The act includes the following notable provisions related to corporate income taxation. Digital assets
See More
Canada plans to enact DST in 2024
On 12 July 2023, Canadian Deputy Prime Minister and Minister of Finance said “two years ago, we agreed to pause the implementation of our own Digital Services Tax (DST), in order to give time and space for negotiations on Pillar One. But we were
See More
UK amends CbC notification Requirement
On 5 July 2023, the House of Commons in the United Kingdom (UK) made a significant decision by accepting Statutory Instrument No. 752/2023 to amend tax regulations on BEPS country-by-country (CbC) notification requirement. The UK government has
See More
Ireland: Revenue issues guidance for platform operators under DAC7
On 5 July 2023, the Irish Revenue issued eBrief No. 155/23, which provides guidance for platform operators for the exchange of information on income generated through digital platforms (DAC7). Council Directive 2011/16/EU (DAC) provides for the
See More
Colombia: Ministry of Finance issues draft decree on significant economic presence rule
On 30 June 2023, the Colombian Ministry of Finance issued a draft decree on the significant economic presence (SEP) rule as a part of Law 2277 of 2022 (tax reform law). The SEP rule was introduced in the context of digital services taxation. The SEP
See More
Luxembourg: Tax Authority updates FAQs on DAC6
On 30 June 2023, the Luxembourg Tax Authority updated the frequently asked questions (FAQs) concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). The latest update clarifies the following measures:
See More
Australia: New legislation proposes amendments to interest limitation rule
Legislation has been introduced in Parliament, suggesting amendment to the interest limitation or thin capitalization rules, which is closely align with the exposure draft legislation. If approved, these rules will be effective for income years
See More
US: IRS publishes practice units on interest expense limitations
On 16 May 2023, the IRS Large Business and International (LB&I) division issued two practice units in relation to interest expense limitations for related party loans. Interest Expense Limitation on Related Foreign Party Loans Under IRC
See More
Transfer Pricing Brief: July 2023
Brazil Scope of transfer pricing rules: On 14 June 2023, the president signed the Law No. 14,596 adopting Provisional Measure No. 1,152, which enacts significant changes to the Brazilian transfer pricing system that is aligned with the
See More
Hong Kong: IRD issues circular letter extending due date for D code returns
On 29 June 2023, the Inland Revenue Department (IRD) published a Circular Letter announcing an extension of the deadline for “D” code profit tax returns. In the letter, IRD explains that given the real difficulties faced by businesses and
See More