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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Singapore updates CbC reporting list of jurisdictions, adds Albania and Georgia
The Inland Revenue Authority of Singapore (IRAS) has updated its list of jurisdictions participating in the Multilateral Competent Authority Agreement (MCAA) for the exchange of Country-by-Country (CbC) reports on 11 October 2024. The recent
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Cyprus revises transfer pricing FAQs
The Cyprus Tax Department announced that it updated its Frequently Asked Questions (FAQs) (English version) on transfer pricing on 24 September 2024. New questions are added from 25 through 43. The main question is 25, which highlights that
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European Commission releases revised list of non-cooperative tax jurisdictions, removes Antigua and Barbuda
The European Commission (EC) announced that European Union (EU) member states have updated the list of non-cooperative tax jurisdictions. The update confirmed that Antigua and Barbuda have been removed from Annex I (the blacklist), while Armenia and
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Ukraine clarifies corporate tax rules for German entities under transfer pricing provisions
The Ministry of Finance of Ukraine has issued a clarification concerning the corporate taxes of the Federal Republic of Germany and their relevance to Ukrainian tax law, particularly in the context of transfer pricing regulations on 30 September
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Italy clarifies DAC7 platform and seller definitions
Italy’s tax authorities issued Law Principle No. 3/2024, on 3 October 2024, clarifying the definitions of "platform" and "seller" to enforce the data reporting obligations for qualifying platform operators, as established by Legislative Decree No.
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Slovak Republic: New bill redefines virtual currencies
The Slovak Republic has enacted a bill to align the Slovak legislation as per the Markets in Crypto-Assets (MiCA) Regulation (2023/1114). The bill pertains to certain obligations and authorisations in the field of crypto active and amending
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European Commission ends infringement case against Germany, Hungary over DAC7 information exchange
The European Commission has announced the conclusion of the infringement procedure against Germany and Hungary for their failure to comply with the obligation to automatically exchange information as mandated by the Amending Directive to the 2011
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Denmark: 2024-25 legislative plan proposes updates to minimum tax, transfer pricing to match OECD rules
Denmark's government announced the legislative programme for the parliamentary year 2024-25 on 1 October 2024. The bill follows up on the government platform "Responsibility for Denmark" from December 2022 and the agreement on "A Stronger Business
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Peru enacts new rules for determining FMV of non-listed securities in related-party transactions
The Peruvian Government enacted Legislative Decree 1663 on 24 September 2024, amending the Income Tax Law to introduce rules for determining the fair market value (FMV) of non-listed securities in related-party transactions. This closes a gap in the
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Chile passes tax compliance bill with income, VAT, transfer pricing measures
Chile’s Senate has approved the Tax Compliance Bill on 24 September 2024, which will be presented to the Lower House for final approval. The newly approved tax measures include modifications to the general anti-avoidance rule (GAAR), statute of
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