Italy implements DAC7 requirements for digital platform operators
The Italian Revenue Agency has declared the release of the Provision of 20 November 2023, outlining the execution of updated reporting and information exchange of information requirements pertaining to income generated by sellers utilizing digital
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Germany: Bundestag approves draft business tax reform bill
On 17 November 2023, the German lower house parliament (Bundestag) passed a bill that seeks to promote economic expansion, stimulate investment, and make the tax system more user-friendly and equitable. Some of the key provisions of the bill
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UK: HMRC publishes guidance on transfer pricing records for PEs
The United Kingdom (UK) HRMC has issued guidance on the transfer pricing records requirements for permanent establishments (PEs) in accordance with the amendments made by Finance (No. 2) Act 2023. The Local files and Master files requirements for
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Kuwait joins the inclusive framework on BEPS
On 15 November 2023, the Organization for Economic Cooperation and Development (OECD) announced that Kuwait joined the inclusive framework on Base Erosion and Profit Shifting (BEPS). Through its membership, Kuwait has also committed to
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Russia: FTS introduce a list of jurisdictions not exchanging CbC reports
The Russian Federal Tax Service (FTS) released a list of jurisdictions that have repeatedly failed to exchange Country-by-Country (CbC) reports electronically with Russia. In cases of systemic exchange failure, a constituent entity within Russia
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Azerbaijan signs MLI to implement tax treaty related BEPS measures
On 20 November 2023, Azerbaijan signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), at a signing ceremony held in Baku. Azerbaijan has become the 102nd jurisdiction to join the BEPS Convention, which
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Greece implements public CbC reporting
On 14 November 2023, Greece published Law No. 5066/2023 in the Official Gazette implementing public Country-by-Country (CbC) reporting in compliance with Directive (EU) 2021/2101. The Law conforms to the directive and sets the public reporting
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Czech Republic approves tax reform measures for FY 2024
The Parliament of the Czech Republic approved the Act on the Consolidation of Public Budgets. Most of the proposed amendments are scheduled to take effect from 1 January 2024. Some of the key tax measures are following: The corporate income tax
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OECD Releases Information and Statistics on Mutual Agreement Procedures
On 14 November 2023 the OECD released the 2022 Mutual Agreement Procedures (MAP) Statistics, covering 133 jurisdictions worldwide. The release of these statistics each year is part of the actions to improve dispute prevention and resolution in line
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Taiwan: MOF reminds taxpayers to submit master file and CbC report by 31st December 2023
On 10 November 2023, Taiwan’s Ministry of Finance (MOF) issued a press release as a reminder to the taxpayers to submit master file and country-by-country (CbC) report. The profit-seeking enterprises that meet the conditions and use the
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Australia: ATO updates guidelines on central management and control test of residency
The Australian Taxation Office (ATO) has released updated guidelines that give foreign companies greater certainty about the compliance under the central management and control test. For better clarification to foreign companies regarding their
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Singapore Gazettes Order Declaring MCAA-CbC
On 6 November 2023, the Singaporean Official Gazette issued Order No. S 714 confirming the effective dates for the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country Reports (CbC) with specific jurisdictions.
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Malta: CfTC launches DAC7 registration portal
On 9 November 2023, the Commissioner for Tax and Customs (CfTC) of Malta launched the registration portal on the reporting obligations of Digital Platform Operators imposed by DAC7 (Council Directive (EU) 2021/514). A Platform Operator must
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South Africa: SARS issues updated guide on taxation
On 1 November 2023, the South African Revenue Service (SARS) issued an updated guide on taxation. This guide providing a high-level overview of the most significant tax legislation administered in South Africa by the Commissioner for the South
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OECD: Consultation on Transfer Pricing Issues Relating to Lithium
On 6 November 2023 the OECD and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) released for public consultation a draft toolkit with the title Determining the Price of Minerals: Application to Lithium. The
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OECD: Guidance on Transfer Pricing Issues for Bauxite
Following the completion of a previous consultation, on 6 November 2023 the OECD published a toolkit with the title Determining the price of minerals: A Transfer Pricing Framework – Schedule A: Bauxite. This toolkit follows on from the publication
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OECD: Practice Note on Transfer Pricing for Minerals
On 6 November 2023 the OECD published the final version of a practice note with the title Determining the price of minerals: A Transfer Pricing Framework. The practice note has been developed after consultation with interested parties with the aim
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Philippines joins the inclusive framework to combat tax avoidance and implement BEPS standards
On 8 November 2023, the Philippines joined as a member of the Organisation for Economic Cooperation and Development (OECD)/G20 Inclusive Framework on Base-Erosion and Profit Shifting (BEPS) Inclusive Framework. The Inclusive Framework on BEPS is
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