OECD introduces new tools to simplify transfer pricing (Amount B)
The OECD has announced the launch of new tools to streamline the implementation of Amount B under Pillar One aimed at simplifying transfer pricing rules. Amount B under the Two-Pillar Solution to Address the Tax Challenges of the Digitalising
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Georgia amends transfer pricing regulations for 2025
Georgia’s Ministry of Finance has announced that it has amended its international controlled transaction regulations through Order No. 331 (issued on 2 October 2024) to align with the latest OECD Transfer Pricing Guidelines. The amendment also
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Switzerland: SIF updates AEOI jurisdictions list, changes status of Belize
The Swiss State Secretariat for International Finance (SIF) released an updated list of jurisdictions participating in the automatic exchange of information (AEOI) on financial accounts on 17 December 2024. Recent updates include a change in
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Australia announces jurisdictions for public CbC reporting
Australia has published the Taxation Administration (Country by Country Reporting Jurisdictions) Determination 2024, listing jurisdictions for public Country-by-Country (CbC) reporting on 12 December 2024. Notably, Liechtenstein has been excluded
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US: Treasury, IRS clarify stance on OECD’s simplified transfer pricing rules
The US Treasury Department and the Internal Revenue Service (IRS) released Notice 2025-04, “Application of the Simplified and Streamlined Approach under Section 482”, on 18 December 2024, clarifying the US government’s stance on using the
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Germany: Ministry of Finance updates transfer pricing guidelines for 2024
The German Ministry of Finance published BMF Letter No. 2024/1078709 on 12 December 2024, updating the guide on transfer pricing for 2024. The new guidelines clarify key aspects of transfer pricing which includes income correction and
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Austria gazettes Pillar Two CbCR Safe Harbour Regulation
Austria’s tax authorities published a decree in the Official Gazette on the temporary CbCR Safe Harbor (CbCR Safe Harbor Regulation) under the Minimum Taxation Act (“MinBestG”) on 5 December 2024. The MinBestG, which came into force on 31
See MoreAustralia updates guidance on public CbC reporting
The Australian Taxation Office (ATO) has revised its guidance on the public country-by-country (CbC) reporting regime focusing on public CbC parent registration requirements on 11 December 2024. Australia’s public CbC reporting is a reporting
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Italy announces penalty relief rules for hybrid mismatch rules
Italy's Ministry of Economy and Finance has published the Decree of 6 December 2024 outlining the penalty reliefs rules for violations of Italy's hybrid mismatch rules. The Decree’s penalty relief rules are taken from Legislative Decree No. 209
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Romania clarifies public CbCR reporting rules
Romania’s Ministry of Finance, in a release, outlined the preliminary format for public Country-by-Country (CbC) reporting. This follows after Romania has introduced public country-by-country (CbC) reporting requirements through Order no. 2.048
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Colombia: DIAN sets tax value unit for 2025
The Colombian National Tax and Customs Directorate (DIAN) issued Resolution No. 000193 on 4 December 2024, setting the tax value unit (UVT) at COP 49,799. The UVT is a tool in the Colombian tax system which allows for the annual update of tax
See MoreAustralia: Pillar Two minimum tax, PCbC reporting, capital gains withholding laws receive royal assent
Australia’s laws related to the Pillar Two minimum tax, Public Country-by-Country (PCbC) reporting requirements, and capital gains withholding received Royal Assent on 10 December 2024. Pillar Two global minimum tax law The Pillar Two global
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Switzerland updates list of participating jurisdictions for AEOI-CRS
The Swiss State Secretariat for International Finance (SIF) released an updated list of jurisdictions participating in the automatic exchange of information (AEOI) on financial accounts on 5 December 2024. This update aligns with the Common
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US, Norway Competent Authority Arrangement (CAA) enters into force
The US Internal Revenue Service (IRS) has issued Announcement 2024-42 on 9 December 2024 in which it notified taxpayers the US and Norway has entered a competent authority arrangement (CAA) in accordance to the paragraph 2 of Article 27 (mutual
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Nigeria: FIRS publishes guidance on advance pricing agreements
Nigeria’s Federal Inland Revenue Service (FIRS) has released detailed guidelines on Advance Pricing Agreements (APAs), providing a framework for companies to establish transfer pricing agreements with tax authorities in advance. Businesses
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Azerbaijan plans to raise penalties for CBC reporting tax non-compliance
Azerbaijan has proposed changes to the Tax Code on penalties for tax non-compliance and country-by-country (CbC) reporting. The penalty for failing to submit requested documents and information to the tax authorities within 60 days will be
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Taiwan reminds taxpayers of Master File, CbC report submission deadlines for FY2023
Taiwan's Ministry of Finance has issued a reminder to taxpayers about the approaching deadline for submitting the Master File and CbC Report for 2023 on 4 December 2024. The Ministry of Finance states that in order to strengthen tax information
See MoreSwitzerland updates MCAA-CbC participation list, adds Armenia, Georgia, Montenegro
An updated the list of participating jurisdictions under the Multilateral Competent Authority Agreement (MCAA) for the exchange of country-by-country (CbC) (Decision No. RO 2024 738) was published in the Swiss Official Gazette on 3 December
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