UK: HMRC publishes transfer pricing guidance on accurate delineation of actual transactions and analysis of risk
On 30 January 2024, the UK HMRC revised its transfer pricing operational guidance by including a new section on the accurate delineation of actual transactions and the analysis of risk. The updated transfer pricing operational guidance is
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Switzerland publishes safe harbor interest rate limits for 2024
On 31 January 2024, the Swiss Federal Tax Administration released two circulars concerning the safe harbor interest rate limits for shareholders and related party financing for 2024. The rates vary based on whether the financing is in Swiss francs
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Cyprus revises thresholds for transfer pricing documentation
On 1 February 2024, the Cyprus Tax Department released updated thresholds regarding the requirement for taxpayers to prepare a Cyprus Local File for intercompany transactions covered by Section 33 of the Income Tax Law (ITL). These revised
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Australia: ATO deliberating on amended interest limitation rules
On 30 January 2024, the Australian Taxation Office (ATO) announced that it is seeking public input and feedback on guidance and advice related to the amendments to the interest deduction limitation rules, also known as thin capitalization rules.
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Australia: ATO issues guidance on hybrid mismatch rules
On 30 January 2024, 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 they should be applied. Australia's hybrid
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Italy: Deadline for initial DAC7 reporting extended
On 30 January 2024, Italy’s Revenue Agency released the Provision (Measure) of 30 January 2024. This legislation is related to the implementation of new regulations regarding the exchange of income information from sellers on digital platforms
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OECD releases ICAP statistics
On 29 January 2024 the OECD released the first aggregated statistics from the Forum on Tax Administration’s International Compliance Assurance Programme (ICAP). ICAP The ICAP is a voluntary risk assessment and assurance program whose
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Germany: Tax authority extends time limit for DAC7 reporting
On 5 January 2024, the German Federal Tax Office declared temporary regulations regarding the reporting requirements outlined in DAC7 for the 2023 reporting cycle, extending the initial deadline until 31 March 2024. DAC7 is designed to tackle
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Belgium implements public country-by-country reporting (CbCR)
On 26 January 2024, Belgium announced the introduction of public country-by-country reporting (CbCR) in the Official Gazette. The new law aligns with the EU Directive 2021/2101 or the EU Public CbCR Directive. On 1 December 2021, the European
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UK: Transfer Pricing and Diverted Profits Tax Statistics
On 25 January 2024 HMRC published the latest set of statistics relating to transfer pricing and the diverted profits tax. The latest release contains data up to end of the 2022/23 tax year. The transfer pricing work is an important part of
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Singapore: IRAS updates list of jurisdictions participating under MCAA-CbC
On 19 January 2024, the Inland Revenue Authority of Singapore (IRAS) updated the list of jurisdictions participating under the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports. Under the
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OECD: Comments Received on Changes to the Commentary to Article 5
On 22 January 2024, the OECD published comments on proposed amendments to the commentary to Article 5 in relation to an alternative provision on activities in connection with the exploration and exploitation of natural resources. The additional
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India: CBDT issues notification for non-resident investors in financial products by IFSC capital market intermediaries
On 4 January 2024, India's Central Board of Direct Taxes (CBDT) issued Notification No. 4/2024 as per the provisions of Section 10, Clause 4G, of the Income Tax Act, 1961. This notification specifically addresses entities who are not residents and
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Switzerland publishes transfer pricing guidelines
On 23 January 2024, the Swiss Federal Tax Administration published the updated Transfer Pricing Guide. The main provisions of the guide include: An overview of the arm's length principle and the consequences of non-compliance under Swiss law.
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Poland announces guide on filing transfer pricing reporting forms
On 23 January 2024, Poland’s Ministry of Finance released a notice outlining the process for submitting transfer pricing reporting (TPR) forms for acquired entities. This requirement applies to tax years commencing after 31 December 2021. The
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Kenya raises fringe benefit tax and non-resident loan interest rates
On 22 January 2024, the Kenya Revenue Authority released a notice related to the market interest rate for fringe benefit tax purposes and the deemed interest rate for non-resident loans for January, February, and March 2024. The market interest
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Belarus modifies transfer pricing rules
On 27 December 2023, Belarus announced that it had made amendments to its transfer pricing rules. The new transfer pricing provisions are outlined in Law No. 327-Z of 27 December 2023, which went into effect on 1 January 2024. The new regulations
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OECD: Update of Estimated Revenue Gains from Pillar Two
On 9 January 2024 the OECD held a webinar to introduce the updated assessment of the projected economic impact of the global minimum tax under Pillar Two of the two pillar solution to international tax. The OECD has used improved methodology and
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