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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Spain releases 2024 FTT list for companies
On 13 December 2023, the Spanish Tax Agency released the list of companies whose market capitalization value surpassed EUR 1 billion as of 1 December 2023. The list pertains to financial transaction tax (FTT). The financial transactions tax (FTT)
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OECD: 2022 Peer Review Reports on the Exchange of Information on Tax Rulings
On 13 December 2023 the OECD released the 2022 Peer Review Reports on the Exchange of Information on Tax Rulings. The latest annual peer review reports cover 131 Inclusive Framework member jurisdictions and jurisdictions of relevance. The BEPS
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Brazil tax reform brings challenges to service sectors
The new Brazilian transfer pricing rules align with the OECD standard and are a radical change to the analysis of intra-group transactions, and offer several implementational challenges. Besides, the tax reform (PEC 45/2019) is being discussed in
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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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