US: IRS issues interim guidance on review and acceptance of advance pricing agreement (APA) submissions
The Internal Revenue Service (IRS) Large Business and International (LB&I) division released a memorandum providing guidance to employees of the Treaty and Transfer Pricing Operations (TTPO) practice area in the Large Business and International
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India: Supreme Court decides high courts responsible for adjudicating transfer pricing cases
On 19 April 2023, the Indian Supreme Court published a decision on whether High Courts should hear appeals challenging the findings of the Income Tax Appellate Tribunal on transfer pricing issues. The judgment pertains to cases where appeals
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Turkey extends several deadlines for tax return and payment
On 25 April 2023, the Turkish Revenue Administration announced the extension of several deadlines for tax returns and payment. Accordingly, the corporate tax return and payment deadline for the accounting period 2022 has been extended to May 5 2023
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Chile: Tax authority clarifies time limits for MAP requests
On 19 April 2023, Circular No. 19 was released by the Chilean tax authority. This circular modifies Circular No. 13, which was published on 18 March 2022, which provides guidance on the Mutual Agreement Procedures (MAP) under Chile’s tax treaties.
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Luxembourg: Government submits draft bill on transfer pricing and general tax procedures
On 28 March 2023, the Luxembourg government submitted Bill No. 8186 to the Parliament. The bill includes changes in advance pricing arrangement (APA), mutual agreement procedure (MAP), compliance with transfer pricing documentation requirements, and
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Norway: MoF launches public consultation proposing to change interest limitation rules
On 12 April 2023, the Norwegian Ministry of Finance launched a public consultation providing a proposal to change the interest limitation rules, which generally limit the deduction of interest expenses for related parties that exceed 25% of EBITDA
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South Africa issues interpretation note on definition of associated enterprise
On 17 April 2023, the South African Revenue Service (SARS) published an interpretation note 128 on the definition of “associated enterprise”. This note provides guidance on the interpretation and application of the definition of “associated
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Hong Kong: IRD issues circular letter extending due date for N code returns
On 14 April 2023, the Inland Revenue Department (IRD) of Hong Kong issued a Circular Letter providing an extension of due date for N code returns. Recognising the genuine difficulties being experienced by businesses and practitioners in their
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Malta: CFR updates FAQs on DAC6
On 13 April 2023, the Maltese Commissioner for Revenue (CFR) updated “frequently asked questions” (FAQs) on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements (DAC6). Accordingly, the following questions
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Algeria: DGI extends the deadline for 2022 annual tax returns
On 12 April 2023, the Algerian Directorate General of Taxes (DGI) issued a communiqué prolonging the deadline for filing tax returns for 2022. Accordingly, the deadline for the 2022 tax return is extended to 31 May 2023 (normally due by 30 April of
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Saudi Arabia: ZATCA approves amendment to the TP Bylaws
On 20 March 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) approved Decision No. 8-2-23 to amend the Transfer Pricing (TP) Bylaws. The approved amendments to the TP Bylaws in Saudi Arabia will expand the scope of the provisions to
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Thailand approves MCAA for automatic exchange of financial account information
On 30 March 2023, Thailand issued a royal decree to implement the Multilateral Competent Authority Agreement (MCAA) for the Automatic Exchange of Financial Account Information. The MCAA was signed by Thailand in July 2022 and allows for information
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Australia releases draft legislation on public CbC reporting requirement
On 6 April 2023, the Australian Treasury Department issued draft legislation outlining the implementation of public country-by-country (CbC) reporting requirements for specific tax-related information to be disclosed by multinational enterprises
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Uganda proposes digital service tax through income tax amendment bill 2023
On 30 March 2023, the Minister of Finance, Planning and Economic Development of Uganda issued Income Tax (Amendment) Bill 2023. Under the bill, Uganda proposes a 5% digital service tax (DST) on every non-resident person deriving income from
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Italy enacts DAC7
On 25 March 2023, Italy published Legislative Decree No. 32/2023 in the Official Gazette for the implementation of EU Council Directive 2021/514 into domestic law on the mandatory automatic exchange of financial account information for digital
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Poland: MoF publishes guideline on transfer pricing method
On 24 March 2023, the Polish Ministry of Finance published guidance clarifying the application of the resale price method to determine the arm's length value of transactions between related parties. The guidance focuses on practical aspects of using
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Brazil: Lower House passes transfer pricing reform measure
On 30 March 2023, the Brazilian Lower House of Congress adopted Measure No. 1,152 to overhaul its transfer pricing system that was introduced on 29 December 2022. In addition to introducing the arm's length principle into the Brazilian transfer
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US and Germany sign CAA regarding CbC exchange arrangement
On 24 March 2023, US and Germany signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. The Competent Authorities desire to conclude this Arrangement on the exchange of CbC Reports based on domestic reporting and
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