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 implements public CbC reporting with a higher threshold
Bulgaria has adopted a new law (Law on Amendments and Supplements to the Accountancy Act) that aligns the country with the EU's public Country-by-Country (CbC) reporting requirement (Directive 2021/2101). This means large companies will be required
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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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Russia: MoF issues guidance on expanded tax regimes for transfer pricing
The Russian Ministry of Finance (MoF) issued Guidance Letter No. 03-12-11/1/126454 on 27 December 2023, providing clarification on the application of Order No. 86n from 5 June 2023. This order expanded the list of states with preferential tax
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Singapore: IRAS updates list of jurisdictions under AEOI-CRS
On 1 February 2024, the Inland Revenue Authority of Singapore (IRAS) revised lists of the jurisdictions involved in reportable and participating jurisdictions in the automatic exchange of information (AEOI) regarding financial accounts under the
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Transfer Pricing Brief: February 2024
Australia Special rules for hybrid instruments or entities: The Australian Taxation Office (ATO) published guidance on the hybrid mismatch rules. The guidance explains why hybrid mismatch rules exist, how hybrid mismatch rules work and when
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