Nigeria: FIRS shifts e-platform for transfer pricing and CbC reporting notifications
Nigeria’s Federal Inland Revenue Service (FIRS), in a notice to taxpayers and the general public, announced the transitioning of the electronic platform for filing transfer pricing returns and country-by-country (CbC) reporting notifications from
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Egypt raises materiality threshold for master file and local file for 2024
On 15 February 2024, Egypt published the Ministerial Decree No. 52 of 2024 in the Official Gazette, providing updated transfer pricing documentation requirements for Egyptian taxpayers. This decree came into effect on 22 February 2024. In this
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Greece proposes new law to implement EU minimum tax rules
On 23 February, 2024, the Greek Ministry of Finance initiated a public consultation on a proposed bill aiming to incorporate the OECD’s Pillar Two Model Rules, as outlined in the EU Minimum Tax Directive. This draft bill is currently open for
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Switzerland releases Q&A guidance on application of transfer pricing rules
On February 23, 2024, the Swiss Federal Tax Authorities (SFTA) published the Q&A guidance regarding the application of transfer pricing regulations in Switzerland. This guidance clarifies the application of the arm's-length principle and the
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Ukraine reports 2023 transfer pricing adjustments results and penalty relief
On 22 February 2024, the State Tax Service of Ukraine published a release about the outcome of the transfer pricing adjustments in 2023. The release mentioned that from 1 August 2023 until the conclusion of martial law in Ukraine, taxpayers can
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France extends DAC7 reporting deadline
The execution of EU Directive 2021/514 (DAC7), which mandates the automatic exchange of income information from digital platforms, is facing hurdles and technical issues in various member states. DAC7 establishes 31 January 2024 as the deadline for
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Slovenia enacts adjustments to permanent establishment and interest limitation regulations
On 9 February 2024, Slovenia officially released the Act amending the Corporate Income Tax Act (ZDDPO-2T) in the Official Gazette. The provisions outlined in the legislation encompass: Preventing PE status misuse: New rules limit on strategies
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Spain mandates DAC7 returns from digital platforms by 8 April 2024
On 31 January 2024, Spain published the Royal Decree 117/2024 in the Official State Gazette in which it outlined the implementation of the due diligence procedures and regulations for the compulsory automatic exchange of information among digital
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Norway issues new guidance on transfer pricing reporting requirements for 2024
On 8 February 2024, the Norwegian Tax Administration (NTA) released a guidance regarding the amendments of the transfer pricing disclosures in tax returns for organizations, due by 31 May 2024 for the fiscal year ending in 2023. The guidance
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Australia holding public consultation on updated public CbC reporting legislation
On 12 February 2024, the Australian Treasury announced it is conducting an additional public consultation regarding implementing new requirements for publishing selected tax information on a Country-by-Country (CbC) basis or public CbC reporting.
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Egypt preparing draft for new income tax law
Egypt’s Minister of Finance for Tax Policy and Reforms has announced plans to draft a new iteration of the Income Tax Law. The details of the new law has been fully published, but the main proposals of the new law include: A focus on
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Malaysia publishes surcharge FAQs related to transfer pricing adjustments
On 18 January 2024, the Inland Revenue Board of Malaysia (IRBM) published an FAQ list about surcharges for transfer pricing adjustments. The FAQ document is available on the transfer pricing guidance webpage. Under the Finance Act 2020, the tax
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Botswana: Finance Minister presents tax reforms and digitalization measures in budget speech 2024
On 5 February 2024, Mr. Peggy O. Serame, Botswana's Minister of Finance and Economic Development presented the 2024 Budget Speech to the National Assembly. The budget contains a number of important tax measures. The key proposed tax measures are as
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Bulgaria: Official Gazette publishes law on public CbC reporting
Bulgaria's Official Gazette published the Law on Amendments and Supplements to the Accountancy Act on 19 December 2023, implementing public Country-by-Country (CbC) reporting as per Directive (EU) 2021/2101. The key points of the law include:
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Japan submits tax reform bill 2024 to parliament
On 2 February 2024, the Japanese Cabinet submitted the tax reform bill 2024 to parliament. The bill covers various tax measures. Key measures of the bill include: Driving Domestic Growth: The introduction of new tax credit incentives is
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Estonia passes draft law for delaying pillar 2 global minimum tax and public CbC reporting
On 8 February 2024, Estonia's Ministry of Finance, in a release announced that it passed the draft legislation to postpone the implementation of the Pillar 2 global minimum tax until the year 2030. Until that time, the companies that fall within the
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Singapore gazettes order announcing MCAA-CbC as international tax agreement with Kenya and Montserrat
On 1 February 2024, the Singaporean Official Gazette issued Order No. S 69, officially recognizing the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) reports as an international tax compliance
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Greece: AADE extends deadline DAC7 reporting
On 26 January 2024, the Greek Public Revenue Authority (AADE) released Circular No. A.1016, outlining the processes for digital platform operators to submit and automatically exchange information in alignment with DAC7. DAC 7, formally known as
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