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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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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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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