Luxembourg clarifies registration and declaration requirements for platform operators under DAC7
On 12 June 2023, the Luxembourg Tax Authority clarified registration and declaration requirements for platform operators for the exchange of information on income generated through digital platforms (DAC7). Platform operators must register with
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UK: Consultation on Changes to Transfer Pricing Rules
On 19 June 2023 the UK government launched a consultation on potential reforms to the UK legislation on transfer pricing, permanent establishments, and diverted profits tax. Transfer Pricing - provision Currently section 147 TIOPA refers to a
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Bahrain plans to introduce corporate income tax
On 24 May 2023, the Bahraini Minister of Finance and National Economy, Mr. Shaikh Salman bin Khalifa Al-Khalifa announced in the parliament that Bahrain is planning to introduce corporate income tax in line with OECD's Pillar Two global minimum tax
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Slovenia adapts tax procedures Act to implement DAC7 regulations
Slovenia has recently introduced amendments to its tax procedures Act in order to implement the provisions of DAC7 (Council Directive EU/2021/514). This directive, adopted on 22 March 2021, seeks to enhance the exchange of information regarding
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Luxembourg: Tax Authority publishes guidance on reverse hybrid rules
On 9 June 2023, the Luxembourg Tax Authority published Circular L.I.R. n° 168quater providing guidance on reverse hybrid mismatch regulations. The Circular aims to provide further clarity on various aspects, including the tax classification of
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UK: Second Reading of Spring Finance Bill 2023
On 13 June 2023 the UK government published the Tax Information and Impact Notes for government amendments at the report stage of the Spring Finance Bill 2023. The Bill includes the following measures: Multinational Top-up tax: UK adoption of
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Canada releases consultation paper on reforming transfer pricing rules
On 6 June 2023, the Canadian Department of Finance issued a consultation paper on reforming and enhancing Transfer Pricing Rules. Budget 2021 announced the government’s intention to consult on Canada’s transfer pricing rules with a view of
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France introduces strict measures to combat international tax fraud
On 5 May 2023, French Minister for public accounts unveils anti-fraud measures targeting international tax and customs activities. Key elements of these measures include lowering the annual turnover threshold that triggers the requirement for
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Kenya: KRA issues notice regarding the declaration of related party transactions
On 5 June 2023, the Kenya Revenue Authority (KRA) has issued a public notice regarding the declaration of related party transactions. Accordingly, taxpayers that the Income Tax - Company Return on the i-tax system has been enhanced to provide
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Spain transposes a bill into domestic law implementing DAC7
On 25 May 2023, an announcement was published in the Spanish Official State Gazette noting that a bill related to implement the EU directive on DAC7 has been enacted to transpose into domestic law. The bill aims to improve the existing tax
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Transfer Pricing Brief: June 2023
Bolivia Filing deadlines: On 28 April 2023, the Bolivian National Tax Service published a Resolution No. 102300000014 extending the corporate income tax (IUE) reporting deadline for the tax year ending 31 December 2022 to 31 May 2023. See
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Nigeria: FIRS releases new guidelines on mutual agreement procedures
On 23 May 2023, the Federal Inland Revenue Service (FIRS) of Nigeria has released Information Circular No. 2023/04 which includes new Guidelines on Mutual Agreement Procedure (MAP). The purpose of the guidelines is to provide guidance on how to
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Malaysia: IRBM gazettes APA Rules 2023
On 29 May 2023, the Malaysian Inland Revenue Board of Revenue (IRBM) published the Income Tax (Advance Pricing Arrangement) Rules 2023 ("APA Rules 2023") in their gazette with the following key changes. Taxpayers engaged in cross-border
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Malaysia: IRBM publishes transfer pricing rules 2023
On 29 May 2023, the Malaysian Inland Revenue Board of Revenue (IRBM) officially published Order No P.U. (A) 165 (TP Rules 2023) introducing a new transfer pricing documentation process effective from assessment year 2023 onwards. The main changes
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Spain releases a law introducing new interest deduction limitation rules
On 25 May 2023, Spain published Law 13/2023 in the Official Gazette, which introduces new interest deduction limitation rules in line with the EU Anti-Tax Avoidance Directive (ATAD). Spain's current rules limiting interest deduction were deemed
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Spain approves corporate income tax return form for tax year 2022
On 22 May 2023, Spain published an “Order HFP/523/2023 of 22 May 2023” in the Official Gazette, approving the forms and instructions for the corporate tax and Non-Resident Income Tax returns for periods starting between 1 January and 31 December
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Portugal extends corporate tax filing deadline to 6 June 2023
On 22 May 2023, the Portugal's Secretary of State for Fiscal Affairs has issued Order No. 148/2023-XXIII. This order grants a brief extension for the submission of the annual corporate tax return and payment for the year 2022. Taxpayers now have
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UAE clarifies interest deduction rules
On 23 May 2023, the United Arab Emirates (UAE) Ministry of Finance (MoF) published Decision No. 126 of 2023 on the general rules for limiting the deduction of interest for corporate tax purposes. To determine the deductible interest from taxable
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