Vietnam deposits BEPS MLI ratification instrument
On 23 May 2023, Vietnam has deposited its instrument of approval for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention). This move makes Vietnam the 81st jurisdiction to
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Luxembourg gazettes law to implement DAC7
On 19 May 2023, Luxembourg published law no 8029 in the Official Gazette to implement new rules on the exchange of information on income generated through digital platforms (DAC7). The law is in accordance with the Council Directive (EU) 2021/514 of
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Albania releases a law amending transfer pricing provisions
On 23 May 2023, Vietnam has deposited its instrument of approval for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention). This move makes Vietnam the 81st jurisdiction to
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Brazil: Federal Senate approves OECD-aligned transfer pricing rules
On 10 May 2023, the Brazilian Federal Senate approved legislation addressing the new transfer pricing which was published on 29 December 2022. This approval is one of the last steps to implement a transfer pricing system in Brazil according to
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Germany approves bill on public CbC reporting directive
On 11 May 2023, the lower house of the parliament (Bundestag) approves a bill to implement EU Directive, requiring publicly disclose CbC report for qualifying Multinational Enterprises (MNEs) operating in the EU. The Public Country-by-Country
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Germany-USA CbC report exchange agreement takes effect
On 10 May 2023, Germany has announced the official entry into force of its Country-by-Country (CbC) Report exchange agreement with the United States, as published in the Official Gazette. The agreement, which became effective on 4 April 2023, marks
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OECD: Consultation Document on Transfer Pricing Issues for Bauxite
On 10 May 2023 the OECD published a consultation document with the title Determining the price of minerals: A Transfer Pricing Framework – Schedule A: Bauxite. This document follows on from the OECD’s toolkit outlining a transfer pricing
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OECD: Consultation Document on Transfer Pricing for Minerals
On 10 May 2023 the OECD published a consultation document with the title Determining the price of minerals: A Transfer Pricing Framework. This is a draft toolkit to support developing countries in combating base erosion and profit shifting relating
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Sri Lanka: IRD publishes MAP guidelines
On 8 May 2023, the Sri Lanka Inland Revenue Department (IRD) has published Mutual Agreement Procedure (MAP) guidelines. The guidelines provide several key aspects related to Mutual Agreement Procedure (MAP) requests in Sri Lanka. The guidelines
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UAE: MoF issues decision on TP documentation requirements
On 11 May 2023, the United Arab Emirates (UAE) Ministry of Finance (MoF) issued Ministerial Decision No. 97 of 2023 on the requirements for maintaining transfer pricing (TP) documentation. Federal Decree Law No (47) of 2023 on the Taxation of
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Australia: Federal Budget for FY 2023-24
On 9 May 2023, Mr. Jim Chalmers, the Australian Treasurer handed down Federal Budget for FY 2023-24, with some proposed changes to tax and superannuation laws. Many of the measures announced are subject to receiving royal assent and therefore not
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Lithuania considers draft order for public CbC Reporting
The Lithuanian parliament (Seimas) is currently considering draft Order 23-4588, which aims to introduce public Country-by-Country (CbC) reporting obligations in line with Directive (EU) 2021/2101. The draft Order specifies the required content of
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Bolivia grants extension for submitting corporate income tax reporting requirements
On 28 April 2022, 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 for (i) financial statements; (ii) annual
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Luxembourg: Parliament approves law to implement DAC7
On 3 May 2023, the Luxembourg Parliament approved law no. 8029 to implement new rules on the exchange of information on income generated through digital platforms (DAC7) in accordance with the Council Directive (EU) 2021/514 of 22 March 2021. The
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US: IRS releases interim guidance on review and acceptance of APA submissions
On 25 April 2023, the Internal Revenue Service (IRS) published a memorandum providing guidance to employees of the Treaty and Transfer Pricing Operations (TTPO) practice area in the Large Business and International Division (LB&I) with respect
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Belgium declares e-Filing services for CIT returns
On 28 April 2023, the Belgian Federal Public Service Finance made an official announcement regarding the launch of the Biztax e-service. This digital platform is aimed at facilitating the submission of corporate income tax (CIT) returns for the
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Transfer Pricing Brief: May 2023
Algeria Filing deadlines: The Algerian Directorate General of Taxes (DGI) has extended the deadline for filing corporate tax returns to 31 May 2023 for the tax year 2022. See the story in Regfollower Brazil Scope of transfer pricing
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Kenya: Transfer pricing tax measures in Finance Bill 2023
On 28 April 2023, the Cabinet Secretary of the Kenya Ministry of Finance submitted the Finance Bill 2023 (the Bill) to Parliament, which provides the following tax measures related to transfer pricing. The bill proposes to prohibit taxpayers from
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