Australia: ATO issues guidance for local file and master file, private property and construction sector company transfer pricing for 2025
The Australian Taxation Office (ATO) has published updated guidance on the local and master file requirements – which applies to reporting periods beginning on or after 1 January 2024 –, and transfer pricing guidance for the private property and
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Sweden consults crypto reporting rules under DAC8 Directive
Sweden’s Ministry of Finance has introduced a proposal to implement Council Directive (EU) 2023/2226 (DAC8), which outlines new reporting and due diligence requirements for crypto-asset service providers. The Ministry is inviting public feedback
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Netherlands updates low-tax and non-cooperative jurisdictions list for 2025
The Netherlands has revised its lists of low-tax and non-cooperative jurisdictions for tax purposes, announcing the removal of Antigua and Barbuda, Belize, and the Seychelles. The lists are used for Dutch tax rules, targeting jurisdictions with
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Czech Republic updates jurisdictions list for MCAA-CRS, CbC report exchange
The Czech Ministry of Finance issued Financial Bulletin No. 1/2025 on 9 January 2025 which updates the list of jurisdictions participating in exchanges under the Multilateral Competent Authority Agreement (MCAA) on automatic financial account
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China publishes 15th APA programme report
China’s State Taxation Administration (STA) has published its 15th annual report on the advance pricing agreement (APA) programme on 26 December 2024. The report provides comprehensive statistical insights into the implementation of the APA
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Russia updates tax information exchange list
Russia’s Federal Tax Service (FTS) has updated its lists of jurisdictions for tax information exchange, effective 31 December 2024. The new changes were announced through two decrees, No. IED-7-17/914 and IED-7-17/916, published on 20 December
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US: Treasury, IRS finalise digital asset reporting rules
The US Treasury Department and Internal Revenue Service (IRS) has published a document (TD 10021) finalising final regulations regarding information reporting by brokers that regularly provide services effectuating certain digital asset sales and
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Iceland announces CbC reporting requirements, deadline for FY 2024
The Icelandic Directorate of Internal Revenue has issued Notice No. 1676/2024, outlining the for country-by-country (CbC) reporting requirements for multinational enterprises for the 2024 fiscal year. As per the notice, entities subject to CbC
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Kazakhstan expands transfer pricing monitoring for cross-border transactions
Kazakhstan has expanded its list of goods, works, and services subject to transfer pricing monitoring. The updated list includes new items such as coal, lignite, hydrogen, polymers, raw aluminium, iron and steel products, various grains like rice
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Lithuania updates CbC reporting rules for MNEs
Lithuania’s tax authority has revised its Country-by-Country (CbC) reporting requirements for multinational enterprises (MNEs), effective from 21 November 2024. All notifications must now be submitted electronically via the "Mano VMI"
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France updates guidelines on royalties declaration under DAC7
French tax authorities clarified that companies managing copyright royalties and inventor rights require companies to include the beneficiary's date of birth in declarations when the recipient is an individual residing in another EU Member State.
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Dominican Republic extends CbC reporting deadline
The Dominican Republic's Directorate General of Internal Revenue (DGII) issued Notice 26-2024 on 2 January 2024, extending the deadline for the submission of Country-by-Country (CbC) reports for 2023 fiscal year to 31 January 2025. The MNE
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Poland sets base and margin rates for transfer pricing
Poland has published Notice No. 1105 in the Official Gazette on 21 December 2024, setting the base interest rates and margin interest rates for transfer pricing in individual and corporate income taxes. The regulation establishes base interest
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Brazil: Revenue authority publishes updated guidance on commodities transfer pricing
Brazil’s revenue authority (Receita Federal) has issued new guidelines for Normative Instruction RFB No. 2246 of 30 December 2024, outlining rules for companies regarding the management of transfer pricing for transactions that involve commodities
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Malaysia updates transfer pricing guidelines, audit framework
Malaysia’s Inland Revenue Board (IRB) has updated transfer pricing guidelines and transfer pricing audit framework. The transfer pricing guidelines have been updated in accordance with the amendments made to section 140A, the introduction of
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The Russian Federal Tax Service (FTS) has updated its list of jurisdictions for automatic exchange of country-by-country (CbC) reports, effective 31 December 2024. The revised list comprises 45 states and 10 territories, compared to the previous
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Australia gazettes instrument regarding Taxation Administration (Country by Country Reporting Jurisdictions) Determination 2024
The Australian Official Gazette, on 17 December 2024, published a legislative instrument for CbC reporting jurisdictions by the Taxation Administration for the year 2024. This instrument includes the list of CbC reporting jurisdictions along with
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Korea (Rep.): National Assembly passes 2024 Tax Law Amendment Bill
The South Korean National Assembly approved the 2024 Tax Law Amendment Bill on 10 December 2024. The amendments will affect various tax regulations which include: Deferral of Crypto Gains Tax The bill introduces a two-year deferral on the
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