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
See MoreAustralia 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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Estonia: Preliminary bill for public CbC reporting submitted to parliament
On 12 February 2024, a draft bill was introduced to the Estonian Parliament to incorporate the EU Public Country-by-Country (CbC) Reporting Directive into Estonian legislation. The parliament acknowledged there are a limited number of companies that
See MoreGermany: MOF issues updated draft guidance on virtual currency transactions
On 6 March 2024, the German Ministry of Finance (MOF) released revised draft guidance concerning the compliance and documentation criteria for transactions involving virtual currency and tokens. This comes after the issuance of a final decree in May
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Germany: Tax authority publishes list of jurisdictions for automatic exchange of financial account information
On 1 March 2023, the German Federal Central Tax Office released the preliminary list of jurisdictions participating in the exchange of financial account information according to the Common Reporting Standard (CRS) for the year 2024, pertaining to
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Italy announces new corporate tax return deadline
Italy has announced new guidelines and procedures for corporate tax return filings for 2024 regarding the tax year 2023. The main change relates to the revised deadline for filing returns as per the corporate tax (IRES) returns. The new
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Cyprus announces 2024 reference rates for notional interest deduction
On 7 March 2024, the Cyprus Tax Department announced the release of reference rates for 2024 that will be used to calculate the notional interest deduction (NID) on new equity investments. According to regulations, the NID rate is equivalent to the
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Canada: CRA releases new circular on advance pricing arrangements (APAs)
On 22 February 2024, the Canada Revenue Agency (CRA) released the Information Circular 94-4R2 on International Transfer Pricing: Advance Pricing Arrangements (APAs). This circular offers detailed guidance on APAs, focusing on the prerequisites for
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Malta publishes guidance note on pillar 2 global minimum tax
Malta's Commissioner for Revenue released a Guidance Note on the European Union Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups Regulations 2024. This guide clarifies Malta’s partial
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Netherlands releases decision on public CbC reporting
On 1 March 2024, the Netherlands released the Decision of February 14, 2024, concerning the enforcement of the Directive (EU) 2021/2101. As previously stated, the Netherlands approved a law for public CbC reporting in December 2023 to partially
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Bolivia defers deadline for submitting and paying financial transaction tax
On 4 March 2024, Bolivia’s tax authority, the National Tax Service (Servicio de Impuestos Nacionales), released the RND N°102400000007. In this guidance, the tax authorities have extended the deadline for submitting affidavits and paying taxes
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Latvia revises domestic list of tax-free or low-tax jurisdictions
On 28 February 2024, the Latvia Ministry of Finance released the updated domestic list of tax-free or low-tax jurisdictions. The renewed list went into effect on 1 March 2024. In the updated list, Latvia removed Belize, Bahamas, Seychelles, Turks
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OECD: Secretary General’s Tax Report to G20 Finance Ministers
On 19 February 2024 the OECD published the Secretary General’s tax report to the G20 Finance Ministers and Central Bank Governors for their meeting of February 2024. The report covered important international tax developments since their previous
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