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 taxÂ
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 jurisdictionsÂ
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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Cyprus extends deadline for 2022 tax return and transaction summary table
On 23 February 2024, the Cyprus Tax Department announced the extension of the deadline for submitting the annual income tax return and summary information table (SIT) for the 2022 tax year. According to the announcement, the deadline has been
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Japan: Platform operators are required to remit consumption tax for foreign e-service providers
On 2 February 2024, Japan's Cabinet presented tax reform bills for the year 2024 to the National Diet. Among the proposed changes is the taxation of platform operators, wherein specific operators would be subject to Japanese consumption tax (JCT) as
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South Africa: Finance Minister presents the Budget for 2024
On 21 February 2024, Enoch Godongwana, South Africa's Minister of Finance announced the budget 2024. Key tax highlights from the 2024 budget following: Enforcing the global minimum corporate tax: The OECD/G20 Inclusive Framework on Base Erosion
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Singapore: IRAS updates list of jurisdictions under CbC reporting
On 23 February 2024, the Inland Revenue Authority of Singapore (IRAS) revised its Country-by-Country Reporting (CbC) guidance page regarding the jurisdictions eligible for automatic exchange of CbC reports. Papua New Guinea has been included in the
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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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