UK considers changes to transfer pricing, advance pricing rules in Autumn Budget 2024
UK’s Chancellor of the Exchequer Rachel Reeves, in her Autumn Budget 2025 announcement on 30 October 2024, said her government is considering modernising the country’s transfer pricing rules and the advance pricing agreement system. Reeves
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Netherlands consults draft bill on implementation of DAC8 rules
The Netherlands Ministry of Finance has initiated a public consultation on a draft bill regarding the implementation of the Amending Directive to the 2011 Directive on Administrative Cooperation (2023/2226) (DAC8). The consultation will commence
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Kazakhstan updates transfer pricing procedures, introduces new local and master file forms
Kazakhstan has issued Order No. 633 of 19 September 2024, which updates Order No. 1104 from 24 December 2018 concerning the forms and procedures for submitting local files, master files, and Country-by-Country (CbC) reports; and introduced new forms
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Singapore gazettes order declaring MCAA-CbC as international tax compliance agreement with Georgia, Albania
Singapore has published Order No. S 813 in the Official Gazette on 24 October 2024 which officially recognises the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports as an international tax
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European Commission adopts DAC9 proposal to ease company filing under Pillar Two Directive
The European Commission has announced it adopted a proposal to amend the Directive on administrative cooperation in the field of taxation (Directive 2011/16/EU – DAC) on 28 October 2024. The goal is to make it easier for companies to fulfil
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India: Tax authority is required to provide justification when rejecting a taxpayer’s chosen transfer pricing method
The Delhi High Court delivered a judgement regarding the tax authority's rejection of SABIC India Pvt. Ltd.'s chosen transfer pricing method, ruling that the tax authority is required to provide justification when rejecting a taxpayer's chosen
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Mexico broadens definition of Digital Intermediation Service in tax law amendment
The Mexican Tax Administration (SAT) has broadened the definition of Digital Intermediation Service for tax law purposes, issued in the Second Resolution of Modifications to the Miscellaneous Fiscal Resolution for 2024 on 11 October 2024. The
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Australia: Australian Greens propose digital services tax
The Australian Parliament Joint Select Committee on Social Media and Australian Society published its Second interim report on digital platforms and the traditional news media. The report addresses several issues and offers specific
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Thailand to join Crypto-Asset Reporting Framework MCAA
The Cabinet of Thailand approved the signing of a commitment letter to participate in the Multilateral Competent Authority Agreement concerning the Automatic Exchange of Information in accordance with the Crypto-Asset Reporting Framework (CARF MCAA)
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France proposes digital services tax rate increase
France’s National Assembly members have proposed on 17 October 2024 to increase the digital services tax rate from the current 3% to 5% in the Finance Bill 2025. The proposed digital services tax rate increase is expected to generate EUR 500
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European Commission updates draft rules for public CbC reporting template, digital formats
The European Commission has released a revised draft of the Commission Implementing Regulation, establishing a standardised template and electronic reporting formats for Public Country-by-Country (CbC) reporting within the EU. This initiative
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CJEU: Netherlands interest deduction limit on acquisition financing upholds freedom of establishment
The Court of Justice of the European Union (CJEU) issued a judgement on 4 October 2024 regarding Dutch interest deduction limits and freedom of establishment (Article 49 TFEU), based on a request from the Netherlands' Supreme Court. The Supreme
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Armenia signs Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports
Armenia signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) on 5 September 2024, according to an OECD update. Armenia's CbC reporting starts on 1 January 2025 for MNE groups with
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Germany passes Fourth Bureaucracy Relief Act, cuts accounting document retention and updates transfer pricing rules
Germany’s Federal Council (Bundesrat) passed the Fourth Bureaucracy Relief Act on 18 October 2024 following its approval by the Bundestag (lower house of parliament) on 26 September 2024. One key aspect of the Act is that it reduces
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Turkey updates transfer pricing communiqué to align with new CbC reporting deadlines
Turkey’s Ministry of Treasury and Finance released General Communiqué No. 5 on Transfer Pricing on 17 October 2014. This Communiqué amends General Communiqué No. 1 on Transfer Pricing and aligns it with new deadlines for Country-by-Country
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UN Tax Committee: Issues in Extractive Industries Taxation
On 15 October 2024 the UN Tax Committee discussed developments in their work on extractive industries taxation. The work of the relevant subcommittee has focused on the energy transition; the valuation of mining products for tax purposes; and tax
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UN Tax Committee: Transfer Pricing Issues
On 16 October 2024 the UN Tax Committee discussed transfer pricing issues. The transfer pricing subcommittee presented for approval a paper on dispute resolution addressing the implementation of advance pricing agreement (APA) programs. The
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Peru approves retroactive application of APAs
The Peruvian Executive Branch has announced the approval of Legislative Decree No. 1662, dated 24 September 2024, which modifies the Advance Pricing Agreement (APA) provision in the income tax law to permit the retroactive application (roll-back) of
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