Algeria announces supplementary finance law for 2023
In November 2023, Algeria published the Supplementary Finance Law for 2023 in the Official Gazette. The key tax measures of the law include: A new transfer pricing declaration obligation has been introduced, requiring taxpayers to submit an
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Costa Rica announces CIT brackets for 2024
On 7 December 2023, the Ministry of Finance of Costa Rica published Executive Decree No. 44276-H in the Official Gazette, outlining the corporate and individual income tax brackets and rates for 2024. The updated corporate income tax is set at
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Hong Kong approves bills to amend asset disposal gain regimes
The Hong Kong Inland Revenue Department passed bills to amend further Hong Kong's refined foreign-sourced income exemption (FSIE) regime, including asset disposal gains and introducing safe harbor rules for onshore equity disposal gains. This
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Ecuador releases updated technical sheet for standardizing the analysis of transfer pricing
On 22 November 2023, the Ecuadorian Tax Authority released a new edition of the technical sheet for the standardization of transfer pricing analysis, effective for fiscal year 2023. This updated document introduces significant changes to filing
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Chile: Digital platform operators must issue pay slips to freelancers
The Chilean tax authority has announced Resolution No. 132 of 20 November 2023, which outlines that digital platform operators must issue electronic third-party service provision pay slips to independent freelancers who provide services to users of
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Transfer Pricing Brief: December 2023
Australia Restriction on interest deduction: On 28 November 2023, the Australian government released the amendments and a supplementary explanatory memorandum to the interest limitation rules within the Treasury Laws Amendment (Making
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Colombia implements comprehensive regulatory framework for taxation of SEP rule
On 27 November 2023, the Colombian Ministry of Finance issued Decree No. 2039, through which Colombia implements comprehensive regulatory framework for taxation of significant economic presence (SEP) rule as a part of Law 2277 of 2022 (tax reform
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Thailand: TRD updates advance pricing arrangements guidance
In October 2023, Thai Revenue Department (TRD) published updated guidance on advance pricing arrangements (APAs). The guidance on APAs has instructions and requirements for bilateral APAs. The update in the guidance mostly related to the
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UN Adopts Resolution to Set Up a Framework Convention on Tax
On 22 November 2023 the UN general assembly adopted a resolution to commence the process of setting up a framework convention on tax. The framework convention could ensure that the UN is the main body for decision-making on international tax
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Australia: Government releases amended interest limitation rule
On 28 November 2023, the Australian government released the amendments and a supplementary explanatory memorandum to the interest limitation rules within the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and
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Canada announces legislation to implement digital services tax
On 28 November 2023, Ms. Chrystia Freeland, Deputy Prime Minister and Minister of Finance, tabled the Notice of Ways and Means Motion to introduce the Fall Economic Statement Implementation Act, 2023. This legislation, which delivers on key
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Poland extends the deadline for submitting certain TPR forms
On 27 November 2023, the Polish Ministry of Finance issued a regulation extending the deadline for the submission of transfer pricing information forms (TPR-P and TPR-C forms) for individual (personal) and corporate income taxes until 31 January
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Norway to implement global minimum tax
On 24 November 2023, the Norwegian government submitted a draft bill to the parliament to enforce Norway's Pillar 2 global minimum tax rules. On 6 June 2023, the Norwegian Ministry of Finance published a consultation paper on implementing the
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France: Tax authority updates transfer pricing guidelines for SMEs
On 22 November 2023, the French tax authority published an updated transfer pricing guide for small and medium-sized enterprises (SMEs). The guide covers a wide range of topics, including the concept of transfer pricing, the arm's length principle,
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Hungary: Parliament passes pillar two global minimum tax law
On 21 November 2023, the Hungarian Parliament passed legislation to implement the Pillar 2 global minimum tax (GloBE) rules as per the Council Directive (EU) 2022/2523 of 14 December 2022. On 17 October 2023, Hungary’s Ministry of Finance
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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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