Australia increases interest rate for simplified transfer pricing record-keeping options for loans
On 8 November 2023, the Australian Taxation Office (ATO) released an updated version of practice compliance guideline on simplified transfer pricing record-keeping options (PCG 2017/2). The updates outline the safe harbor interest rate for the
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Ireland: Revenue publishes registration guidelines for platform operators under DAC7
On 6 November 2023, the Irish Revenue issued eBrief No. 235/23, which provides registration Guidelines for platform operators for the exchange of information on income generated through digital platforms (DAC7). With effect from 1 January 2024,
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US: IRS introduces new measures to ensure tax payment by major corporations
On 20 October 2023, the US IRS announced new initiatives funded by the Inflation Reduction Act. These initiatives. These new initiatives aim to ensure that large corporations pay their outstanding taxes and intensify IRS efforts in pursuing
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Hungary approves new CbC exchange agreement with the US
On 2 November 2023, Hungary formally approved signing a new Country-by-Country (CbC) exchange agreement with the United States. The agreement—Decree No. 1482/2023—was published in the Official Gazette. This follows the previous CbC exchange
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Cyprus consents to the Pillar Two QDMTT and the transitional UTPR Safe Harbours
On 30 October 2023, the government of Cyprus released a press release announcing its consent to the design and application of the transitional Undertaxed Profits Rule (UTPR) Safe Harbour and the permanent Qualified Domestic Minimum Top-up Tax
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Albania introduces new income tax framework, bringing significant changes from 2024
On 20 September 2023, Albania released Income Tax Instruction No. 26 in the Official Gazette, laying the groundwork for the enforcement of Income Tax Law No. 29/2023. The Income Tax Law No. 8438/1998 was repealed and replaced by Law No. 29/2023,
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Hungary: MOF introduces draft legislation on BEPS 2.0 pillar two to parliament
On 31 October 2023, the Hungarian Ministry of Finance presented the draft legislation to the parliament regarding the implementation of EU Directive 2022/2523 on the global minimum tax. As previously reported, the Ministry of Finance released
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Saudi Arabia: ZATCA releases drafts of new income tax and tax procedural laws for public consultation
On 25 October 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued drafts of a new Income Tax Law and Zakat and Tax Procedures Law for public consultation. The public consultation period for comments on the drafts is open until 25
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Italy: Revenue agency issues draft guidelines on investment management transfer pricing
On 20 October 2023, the Italian Revenue Agency issued the draft transfer pricing guidelines for implementing the Investment management exemption regime (IME). The draft was in public consultation until 3 November 2023. The IME was introduced by
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Transfer Pricing Brief: November 2023
Australia Documentation: The Australian Tax Office (ATO) has announced that taxpayers with CbCR obligations for the year ending 31 December 2022 will now have until 31 January 2024 to submit their reports. This extension applies to the CbC
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Singapore: IRAS updates list of jurisdictions participating under MCAA-CbC
On 30 October 2023, 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 list:
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Kuwait set to implement corporate income tax for all entities
According to a recent report, the Kuwaiti government is planning to broaden the scope of corporate income tax to include all entities in Kuwait at a rate of 15%, except for small enterprises. Currently, the CIT is 15% for foreign companies carrying
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Malta pushes back initial DAC7 registration deadline
On 27 October 2023, the Maltese Commissioner for Tax and Customs notified that Version 1.2 of the updated guidelines on the reporting obligations of Digital Platform Operators imposed by DAC7 (Council Directive (EU) 2021/514), has been issued
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UAE: FTA releases transfer pricing guide
On 23 October 2023, the Federal Tax Authority (FTA) of the United Arab Emirates (UAE) released the Transfer Pricing Guide. This guide is designed to provide general guidance on the Transfer Pricing regime in the UAE with a view to making the
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Ireland: Revenue updates guidance for platform operators under DAC7
On 23 October 2023, the Irish Revenue issued eBrief No. 231/23, which provides updated guidance for platform operators for the exchange of information on income generated through digital platforms (DAC7). The provisions relating to the reporting
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Poland: MoF extends transfer pricing reporting deadline for 2022
On 27 October 2023, the Ministry of Finance in Poland decided that it planned to extend the deadline for submitting transfer pricing reporting forms (TPR-P and TPR-C) by 3 months, from 30 November 2023 to 29 February 2024. This extension is due to
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Australia extends deadline for submitting CbC reports, Master file & Local file
The Australian Tax Office (ATO) has announced that taxpayers with country-by-country (CbC) reporting obligations for the year ending 31 December 2022 will now have until 31 January 2024 to submit their reports. This extension applies to the CbC
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UN Tax Committee considers transfer pricing and treaty issues
The 27th session of the UN Committee of Experts on International Cooperation in Tax Matters took place from 17 to 20 October 2023. Subcommittees dealing with various areas of taxation presented updates to the Tax Committee on their
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