Netherlands publishes DAC7 FAQs
On January 1, 2024, the Netherlands’ tax authorities released a series of frequently asked questions (FAQs) to clarify the Netherlands’ reporting obligations and procedures under DAC7. The FAQs provide details regarding specific key terms,
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South Korea approves 2024 tax reform bill and postpones undertaxed profits rule
On December 31, 2023, South Korea implemented the 2024 Tax Reform Bill (the 2024 Tax Reform) after approval from Korea's National Assembly on 21 December 2023. The 2024 Tax Reform will take effect for fiscal years starting on or after 1 January 1,
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Indonesia releases revised guidelines for transfer pricing
On 29 December 2023, Indonesia’s Minister of Finance (MoF) released the revised transfer pricing guidelines Regulation No. 172 of 2023 (PMK-172). The updated and consolidated transfer pricing regulations in various chapters, such as: General
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Poland publishes guidance on transfer pricing, base interest rates, and margin rates
On 29 December 2023, Poland’s Ministry of Finance released the guide on submitting transfer pricing information, which includes: Detailed FAQs related to the obligation to submit transfer pricing information; entity identification
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US: IRS evaluating group membership to fix arm’s length interest rate
On 29 December 2023, the Office of Chief Counsel Memorandum announced that the IRS is considering group membership to determine the arm's length interest rate chargeable for intragroup loans and make a section 482 adjustment. The memorandum provides
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Netherlands updates low-tax and non-cooperative jurisdictions list for 2024
On 29 December 2023, the Dutch State Secretary of Finance published an end-of-year regulation in the Official Gazette. The regulation has been updated to revise the lists of low-tax and non-cooperative jurisdictions for tax purposes. Effective
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Ireland publishes new guidance on requesting TP documentation
On 18 December 2023, the Irish Revenue issued eBrief No. 261/23 providing a new Tax and Duty Manual Part 35a-01-05 - Requests for Transfer Pricing (TP) Documentation. This Tax and Duty Manual documents the operational policy of the Transfer
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Germany: Bundesrat approves secondary credit market promotion Act
On 14 December 2023, upper house of parliament (Bundesrat) granted approval to the Secondary Credit Market Promotion Act. The Act had already received approval from the German Bundestag (lower house of parliament) on 13 December 2023 and is
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Belgium enacts law on public CbC reporting
On 21 December 2023, the Belgian Chamber of Representatives passed a legislation for enacting the public Country-by-Country (CbC) reporting as required by Directive (EU) 2021/2101. The Directive mandates that a company is subject to public
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Colombia announces new TP documentation deadlines for 2023 and later
On 22 December 2023, Columbia released Decree 2229, introducing revised deadlines for submitting various forms of transfer pricing documentation. These include the informative declaration, country-by-country (CbC) notification, Local file, Master
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Malta releases guidelines about notional interest deduction (NID) rules
On 20 December 2023, Malta's Commissioner for Revenue published Version 1.1 of the Guidelines in Relation to the Notional Interest Deduction (NID) Rules. The Version 1.1 updates the sections regarding notional interest deduction (NID) approval,
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Latvia finalizes implementation of DAC7
On 6 December 2023, Latvia issued the Law of 6 December 2023 on Amendments to the Law on Taxes and Fees (Duties). The law allows for enforcing the joint audit rules of Council Directive (EU) 2021/514 concerning the exchange of income information
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Iceland announces CbC notification deadline for 2023
On 19 December 2023, Iceland published Notice 1525/2023 in the Official Gazette. The notice stipulates that the CbC report notification for the 2023 fiscal year must be submitted within one month from the year's end (by 31 January 2024, for the
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Hungary offers tax amnesty for previously ineligible shares
Recently, Hungary implemented a tax legislation that grants one-time amnesty for any capital gains on the disposal of shares in subsidiaries that had not previously chosen to participate in Hungary's capital gains exemption regime. Hungary’s
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Kazakhstan’s Transfer Pricing Legislative Amendments 2023
Kazakhstan is undergoing a pivotal transformation in its transfer pricing framework, marked by the Majilis' approval of substantial amendments to the existing legislation. The aim is to curb revenue losses, prevent capital outflow, and align with
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Russia announces transfer pricing changes from 2024
On 27 November 2023, Russia issued Law No. 539-FZ in the Official Gazette, which outlines several amendments to the country’s transfer pricing regime. A summary of several key changes is outlined below: Secondary adjustments treated as
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Papua New Guinea: BEPS MLI enters into force
On 1 December 2023, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Papua New Guinea. Regarding the tax treaties between Papua New Guinea and other
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Netherlands: Senate passes public CbC reporting bill
The Dutch Senate (upper house of parliament) has passed the bill for implementing public Country-by-Country (CbC) reporting as required by Directive (EU) 2021/2101. The bill facilitates the partial implementation of Council Directive (EU) 2021/2101,
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