Hungary ratifies new CbC reporting pact with US
Hungary’s President has signed Law No. XLIII of 2024, officially ratifying the new Country-by-Country (CbC) reports exchange agreement with the US. The ratification was published in the Official Gazette No. 113 (Magyar Közlöny) on 13 November
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EU releases updated public CbC reporting forms
The European Commission (EC) published a revised regulation that provides the common template and electronic reporting formats for the EU public country-by-country (CbC) reporting directive on 21 October 2024. This follows after the conclusion of
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Germany: MoF publishes draft bill revising participating jurisdictions for MCAA-CbC exchange
The German Ministry of Finance (MoF) issued a draft bill proposing updates to the list of jurisdictions participating in the Multilateral Competent Authority Agreement (MCAA) for the exchange of country-by-country (CbC) reports on 14 November 2024.
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Bulgaria to sign CARF MCAA for crypto-asset reporting
The Council of Ministers of Bulgaria has approved the signing of the Multilateral Competent Authority Agreement for the Automatic Exchange of Information under the Crypto-Asset Reporting Framework (CARF MCAA) on Wednesday, 13 November 2024. The
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Hungary considers retail tax extension for online marketplaces
Hungary's parliament is currently discussing Draft Bill T/9724, which proposes to extend the retail sales tax to include online marketplaces. The bill is expected to go into force on 1 January 2025. Hungary implemented a retail sales tax on
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Australia: ATO extends CbC reporting deadlines
The Australian Taxation Office (ATO) announced, on 13 November 2024, an extension for the filing deadline of country-by-country (CbC) reporting entities for the year ending 31 December 2023. The deadline has been extended until 31 January
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Peru: Congress approves bill to ratify MLI
The Economy, Banking, Finance, and Financial Intelligence Committee of the Peruvian Congress approved a bill to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 6
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Luxembourg updates CbC reporting guidance
The Luxembourg Administration of Direct Tax has updated its Country-by-Country (CbC) reporting guidance page, including an updated CbC reporting FAQ, to reflect the latest OECD recommendations. The update addresses whether profits (losses) before
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Bangladesh: NBR to conduct first transfer pricing audit to tackle tax evasion
Bangladesh tax authority National Board of Revenue (NBR) announced that it will conduct its first transfer pricing audit of multinational companies (MNCs) operating in the country. Bangladesh first introduced transfer pricing provisions in the
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Chile details VAT representative process for foreign digital platforms
Chile’s Tax Administration (Servicio de Impuestos Internos, SII) has issued Resolution Ex. SII 101-2024 was published on 24 October 2024, outlining guidelines for digital platform companies not based in Chile regarding the appointment of a Chilean
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Costa Rica issues framework for automatic exchange of information for digital platform sellers
Costa Rica’s Ministry of Finance issued resolution MH-DGT-RES-0025-2024 in the Official Gazette on 6 November 2024, establishing a framework for automatically exchanging information concerning sellers operating on digital platforms. The
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UK Treasury revises reporting rules for digital platforms
The UK Treasury has updated its regulations for digital platform operators on 31 October 2024. The UK Treasury introduced “The Platform Operators (Due Diligence and Reporting Requirements) (Amendment) Regulations SI 2024/1082 (Regulations SI
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Ireland approves new global tax reform rules
Ireland's parliament has passed a bill simplifying transfer pricing for marketing and distribution and amending global minimum tax rules on 6 November 2024. This legislation was enacted as part of the Finance Bill 2024, which was approved by both
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Hungary approves CbCR IGA with the US
Hungary’s parliament passed the 2024 Hungary-US Agreement on the Automatic Exchange of Country-By-Country (CbC) Reports on 4 November 2024. The CbC agreement was signed on 15 July 2024 by Hungary and on 1 August 2024 by the US. The newly
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Germany gazettes Fourth Bureaucracy Relief Act to ease VAT obligations
Germany’s parliament enacted the Fourth Bureaucracy Reduction Act, published it in the Official Gazette 29 October 2024, with the aim to shorten document retention periods and simplify various VAT-related obligations. One key aspect of the Act
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Argentina issues transfer pricing rules for SPV transactions under large investment incentive regime
Under the new rules, SPVs must annually file transfer pricing analyses with the ARCA for both local and international transactions, including those in low- or no-tax jurisdictions, and may engage in Contribution and Cost Sharing
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US: IRS and Treasury Plan to Issue Guidance on Streamlined Approach to Baseline Distribution Activities
In the IRS and Treasury Priority Guidance Plan for 2024/25, issued on 3 October 2024, there is a plan for a new section 482 guidance project to provide guidance for taxpayers consistent with Amount B of Pillar One. The OECD Amount B Guidance
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Chile updates tax compliance law, introduces changes to GAAR, transfer pricing, and CFC
Chile's Internal Revenue Service (SII) has announced that the Law on Compliance with Tax Obligations (Law No. 21.713) has been published in the Official Gazette on 24 October 2024. General and Special Anti-Avoidance Rules changes The General
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