Hungary approves CbCR IGA with the US
Hungary’s parliament passed the 2024 Hungary-US Agreement on the Automatic Exchange of Country-By-Country (CbC) Reports on 4 November 2024. The CbC agreement was signed on 15 July 2024 by Hungary and on 1 August 2024 by the US. The newly
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Germany gazettes Fourth Bureaucracy Relief Act to ease VAT obligations
Germany’s parliament enacted the Fourth Bureaucracy Reduction Act, published it in the Official Gazette 29 October 2024, with the aim to shorten document retention periods and simplify various VAT-related obligations. One key aspect of the Act
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Argentina issues transfer pricing rules for SPV transactions under large investment incentive regime
Under the new rules, SPVs must annually file transfer pricing analyses with the ARCA for both local and international transactions, including those in low- or no-tax jurisdictions, and may engage in Contribution and Cost Sharing
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US: IRS and Treasury Plan to Issue Guidance on Streamlined Approach to Baseline Distribution Activities
In the IRS and Treasury Priority Guidance Plan for 2024/25, issued on 3 October 2024, there is a plan for a new section 482 guidance project to provide guidance for taxpayers consistent with Amount B of Pillar One. The OECD Amount B Guidance
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Chile updates tax compliance law, introduces changes to GAAR, transfer pricing, and CFC
Chile's Internal Revenue Service (SII) has announced that the Law on Compliance with Tax Obligations (Law No. 21.713) has been published in the Official Gazette on 24 October 2024. General and Special Anti-Avoidance Rules changes The General
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UK considers changes to transfer pricing, advance pricing rules in Autumn Budget 2024
UK’s Chancellor of the Exchequer Rachel Reeves, in her Autumn Budget 2025 announcement on 30 October 2024, said her government is considering modernising the country’s transfer pricing rules and the advance pricing agreement system. Reeves
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Netherlands consults draft bill on implementation of DAC8 rules
The Netherlands Ministry of Finance has initiated a public consultation on a draft bill regarding the implementation of the Amending Directive to the 2011 Directive on Administrative Cooperation (2023/2226) (DAC8). The consultation will commence
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Kazakhstan updates transfer pricing procedures, introduces new local and master file forms
Kazakhstan has issued Order No. 633 of 19 September 2024, which updates Order No. 1104 from 24 December 2018 concerning the forms and procedures for submitting local files, master files, and Country-by-Country (CbC) reports; and introduced new forms
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Singapore gazettes order declaring MCAA-CbC as international tax compliance agreement with Georgia, Albania
Singapore has published Order No. S 813 in the Official Gazette on 24 October 2024 which officially recognises the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports as an international tax
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European Commission adopts DAC9 proposal to ease company filing under Pillar Two Directive
The European Commission has announced it adopted a proposal to amend the Directive on administrative cooperation in the field of taxation (Directive 2011/16/EU – DAC) on 28 October 2024. The goal is to make it easier for companies to fulfil
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India: Tax authority is required to provide justification when rejecting a taxpayer’s chosen transfer pricing method
The Delhi High Court delivered a judgement regarding the tax authority's rejection of SABIC India Pvt. Ltd.'s chosen transfer pricing method, ruling that the tax authority is required to provide justification when rejecting a taxpayer's chosen
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Mexico broadens definition of Digital Intermediation Service in tax law amendment
The Mexican Tax Administration (SAT) has broadened the definition of Digital Intermediation Service for tax law purposes, issued in the Second Resolution of Modifications to the Miscellaneous Fiscal Resolution for 2024 on 11 October 2024. The
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Australia: Australian Greens propose digital services tax
The Australian Parliament Joint Select Committee on Social Media and Australian Society published its Second interim report on digital platforms and the traditional news media. The report addresses several issues and offers specific
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Thailand to join Crypto-Asset Reporting Framework MCAA
The Cabinet of Thailand approved the signing of a commitment letter to participate in the Multilateral Competent Authority Agreement concerning the Automatic Exchange of Information in accordance with the Crypto-Asset Reporting Framework (CARF MCAA)
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France proposes digital services tax rate increase
France’s National Assembly members have proposed on 17 October 2024 to increase the digital services tax rate from the current 3% to 5% in the Finance Bill 2025. The proposed digital services tax rate increase is expected to generate EUR 500
See MoreEuropean 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
See MoreCJEU: 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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