Ireland: Irish Revenue updates tax manuals for outbound payments defensive measures
On 11 April 2024, the Irish Revenue issued eBrief No. 119/24 regarding to the updates on the tax and duty manuals related to the new outbound payments defensive measures. The outbound payments defensive measures are included in the Finance (No.2)
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Poland passes law for implementing DAC7
On 9 April 2024, Poland's Council of Ministers passed a bill to enact new regulations for exchanging information on income generated from sellers on digital platforms, or DAC7. These rules are outlined in Council Directive (EU) 2021/514, which was
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MoF in Ethiopia issues new transfer pricing directive
The Ethiopian Ministry of Finance (MoF) released Directive No. 981/2024 (referred to as "The Directive"), introducing new transfer pricing regulations, concerning the pricing of international and domestic transactions between related persons whose
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Ireland: Irish Revenue publishes guidance on outbound payment measures
On 25 March 2024, the Irish Revenue released eBrief No. 096/24 outlining new guidance on Outbound payments defensive measures. This latest guidance has been issued as part of the Finance (No.2) Act 2023. The Finance (No.2) Act 2023 inserted Chapter
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Czech Republic announces draft legislation for enacting DAC8
On 25 March 2024, the Czech Republic government announced the release of the Draft Bill amending the Act on International Cooperation in Tax Administration and Other Related Acts to implement Council Directive (EU) 2023/2226 of 17 October 2023. This
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Hungary releases 2024 audit plan with targets transfer pricing
Hungary's National Tax and Customs Administration (NAV) has released its audit strategy for the 2024 calendar year, highlighting transfer pricing as its key area of focus among other sectors. The new transfer pricing reporting obligation introduced
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Germany: Parliament approves law for growth, investment, and tax simplification
The Bundesrat, upper chamber of the German Parliament, gave its approval to the compromise proposal for the "Act aimed at Enhancing Growth Opportunities, Investment, and Innovation, while Simultaneously Simplifying Taxation and Ensuring Fairness" on
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Cyprus announces updates to its transfer pricing FAQs
On 28 March 2024, the Cyprus Tax Department released the updated version of its English-language Frequently Asked Questions (FAQs) on transfer pricing. The FAQs present the questions and the corresponding answers as published on the Tax
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Comparative Tax Revenue Effects of Amount A and Digital Service Tax Regimes
As authors of several studies that estimate the tax revenue impact of Amount A for various countries and compare the Amount A impact with revenues from a model digital service tax (DST) regime, we observed certain patterns that hold true for various
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Poland introduces new reporting legislation for digital platform operators (DAC7)
On 22 March 2024, Poland announced a new legislation for the implementation of the Council Directive (EU) 2021/514, known as DAC7. The bill was published on the Government Legislation Centre's website. The legislation introduces several key
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Germany: Bundesrat approves growth opportunities Act
On 22 March 2024, the German upper house of parliament (Bundesrat) declared its endorsement of the Growth Opportunities Act. The lower house of parliament (Bundestag) gave its approval to the Act on 23 February 2024. The bill, initially proposed as
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Ukraine revises form and procedures for county-by-country (CbC) reports
The State Tax Service of Ukraine released updates to the form and procedures for preparing country-by-country reports. Among the main changes to the procedure for filling out the country-by-country report of the international group of companies
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Poland: Parliament passes public CbC reporting legislation
The Polish Parliament has passed a law implementing public Country-by-Country (CbC) reporting in accordance with the requirements of Directive (EU) 2021/2101. This legislation establishes a public reporting threshold for companies with annual
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Colombia: CUP method valid for commodity transactions without quoted prices
The Colombian Tax Authority (DIAN) released Ruling 1118 (Int. 81) of 13 February 2024, which provides clarification of the application of the Comparable Uncontrolled Price (CUP) method for commodity transactions between related parties that do not
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Lithuania sign MCAA to exchange information with respect to income earned on digital platforms
On 4 March 2024, Lithuania signed the multilateral competent authority agreement (MCAA) on the automatic exchange of information on income derived through digital platforms, according to an update published by OECD on 12 March 2024. The DPI-MCAA
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Germany: Federal central tax office issues updated CRS manual
On 5 March 2024, the German Federal Central Tax Office (BZSt) published Newsletter No. 01/2024, addressing updates on the common reporting standard (CRS). Notably, the newsletter announces an extension of the deadline for the non-objection waiver
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Australia: ATO initiates consultation on draft tax determination for hybrid mismatch rules
The Australian Taxation Office (ATO) released the draft Taxation Determination (TD) 2024/D1 - Income tax: hybrid mismatch rules - application of certain aspects of the 'liable entity' and 'hybrid payer' definitions. This draft Determination
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Australia initiates consultation on transfer pricing rules for petroleum resource rent tax
On 18 March 2024, the Australian Treasury announced that it initiated a public consultation on Petroleum Resource Rent Tax transfer pricing regulations. The deadline for receiving comments on the matter is set at 12 April 2024. In the 2023 24
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