New Zealand issues Commissioner’s Statement on withholding in transfer pricing

04 September, 2024

The New Zealand tax authority released the Commissioner's statement (CS) 24/02: Withholding obligations arising in relation to transfer pricing arrangements on 30 August 2024. CS 24/02 details the Commissioner's stance and operational strategy

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Brazil consults transfer pricing rules for intragroup services, unilateral APAs

03 September, 2024

Brazil's Federal Revenue Service (RFB) announced a public consultation on draft guidelines for transfer pricing regulations for intragroup services and unilateral advance pricing agreements under Brazil's new transfer pricing regime on 29 August

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US seeks USMCA dispute settlement talks over Canada’s digital services tax

02 September, 2024

The US Trade Representative Katherine Tai announced that the US has requested dispute settlement consultations with Canada under the United States-Mexico-Canada Agreement (USMCA) regarding Canada’s recently enacted digital service tax (DST) on 30

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Macau authorises AEOI signing with Hong Kong

28 August, 2024

Macau authorised the signing of an agreement with Hong Kong for the automatic exchange of tax information on financial accounts (AEOI). The order – Chief Executive Order No. 45/2024 – in the Official Gazette on Monday, 26 August 2024. The

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Italy: Country File of transfer pricing documentation must be submitted in Italian

22 August, 2024

The Italian Revenue Agency issued its response to Ruling No. 174 on 21 August 2024, clarifying that the Italian the Country File (National Documentation) must be prepared and submitted in Italian language upon request. The Country File (National

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Singapore updates CbC reporting jurisdictions, adds Ukraine

21 August, 2024

The Inland Revenue Authority of Singapore (IRAS) has revised the list of jurisdictions for exchanging Country-by-Country (CbC) reports under the Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (2016)

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EU Commission consults CbCR template, electronic formats 

20 August, 2024

The European Commission (EC) initiated a public consultation regarding draft legislation for a common template and electronic formats for public country-by-country (CbC) reports on 1 August 2024. Large multinational corporations operating in the

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UK launches consultation on safe harbour anti-arbitrage rule transition to domestic law

19 August, 2024

The UK Treasury released draft legislation for consultation on implementing the transitional safe harbour anti-arbitrage rule. This initiative ensures the rule aligns with the OECD's G20 Inclusive Framework's December 2023 Administrative

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Germany revises transfer pricing guidelines for intra-group financing

16 August, 2024

Germany’s Federal Ministry of Finance (BMF) has issued a draft version of the Administrative Principles for Transfer Pricing 2023 (VWG VP), on 14 August 2024. This revision incorporates the new regulations found in Section 1, Paragraphs 3d and 3e

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US: IRS consults updated draft form for reporting digital asset transactions

15 August, 2024

The US Internal Revenue Service released IR 2024-204 on 9 August 2024, which contains an early draft of the updated Form 1099-DA. This form is for brokers to report certain sale and exchange transactions of digital assets that take place beginning

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US: Kansas updates transition rules after separating from federal interest deductions

15 August, 2024

The Kansas Department of Revenue published Notice 24-16, on 7 August 2024, providing guidance on business interest deductions for tax years 2021 and beyond. For tax years 2018, 2019, and 2020, Kansas was coupled with the federal code and only

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Ukraine: MCAA for financial data exchange enters into force

13 August, 2024

Ukraine's Ministry of Foreign Affairs published Letter No. 72/14-612-106482, on 5 August 2024, stating that the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (MCAA) entered into force for Ukraine

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Google ads to cost more in Canada

13 August, 2024

According to a new Google update on jurisdiction-specific surcharges guidance, Google Ads will implement an additional fee for ads displayed in Canada. This surcharge aims to help offset the costs associated with complying with the country's new

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Ireland updates guidance on exchange of information

12 August, 2024

Irish Revenue has released eBrief No. 210/24, on 6 August 2024, which provides updated guidance on information exchange. The Guide to Exchange of Information under Council Directive 2011/16/EU, Ireland’s Double Taxation Agreements and Tax

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Japan publishes guidance on consumption tax rules for online platforms

09 August, 2024

Japan's National Tax Agency (NTA) has issued new rules for the collection of consumption tax by online platform operators, which will apply from 1 April 2025. Businesses who provide electronic services such as application distribution for the

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UK: HMRC publishes digital platform reporting guidelines

08 August, 2024

The UK HMRC published a guidance on Reporting rules for digital platforms on the UK’s implementation of the OECD’s Model Rules for Platform Reporting, on 1 August 2024, outlining the reporting requirements for individuals selling goods or

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Turkey extends Q2 2024 provisional tax return deadline

08 August, 2024

Turkey's Revenue Administration has announced an extension for the submission of the provisional tax return for the second quarter of the 2024 accounting period. The deadline has been moved from 19 August 2024 to 27 August 2024. Normally,

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Argentina: Foreign affairs committee approves BEPS agreement

07 August, 2024

Argentina's Chamber of Deputies' Budget and Finance Committee approved the draft legislation for ratifying the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 31 July,

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