Transfer Pricing Brief: October 2023
Armenia Compliance with BEPS standards: On 25 September 2023, Armenia deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI). See the story in
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France submits finance bill for 2024 including Pillar 2 global minimum tax
On 27 September 2023, the government of France presented the 2024 Finance Bill to Parliament. The bill aims to combat inflation, reduce the national debt and promote sustainable development. The Finance Bill includes a provision to implement the
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Latvia publishes law transposing public CbC reporting into domestic law
On 27 September 2023, the Latvian government released the "Information on Revenue and Income Tax Disclosure Law" in the Official Gazette. This law outlines the framework for the adoption of public Country-by-Country (CbC) reporting, aligning Latvia
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Poland releases guidelines relating to cost-plus method in transfer pricing
On 29 September 2023, Poland published formal guidance regarding the application of the cost-plus method to ensure accurate valuation of transactions involving related entities for international tax purposes. The purpose of this guide is to provide
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Armenia deposits its instrument for the ratification of BEPS MLI
On 25 September 2023, Armenia deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI). The Convention will enter into force in relation to Armenia on 1
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Austria: Ministry of Finance releases DAC6 reporting guidelines
On 12 September 2023, the Austrian Ministry of Finance published an updated guidance on the explanation and application of the rules of DAC6 in Austria. This update is a practical guide to understanding EU-MPfG compliance, based on questions and
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OECD: Sixth Annual Peer Review Report on BEPS Action 13
On 25 September 2023 the sixth annual peer review report was issued under BEPS Action 13, looking at the implementation of the minimum standard on country by country (CbC) reporting by jurisdictions at April 2023. The report covers 136 member
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North Macedonia updates TP report submission requirements
On 25 September 2023, North Macedonia officially published amendments to the Profit Tax Law in Official Gazette No.199. According to the amendments, the requirement to submit transfer pricing reports is terminated with effect from 1 January 2024. As
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Ecuador: SRI gazettes resolution amending transfer pricing rules
On 13 September 2023, Ecuador's Internal Revenue Service (SRI) issued Resolution No. NAC-DGERCGC23-00000025, which modifies the transfer pricing rules. The resolution includes following measures: Taxpayers who have conducted transactions with
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OECD: Responses to Consultation on Amount B of Pillar One
On 20 September 2023 the OECD published the responses to the consultation on Amount B of Pillar One of the two-pillar approach to taxation of the digital economy. Amount B applies to baseline marketing and distribution activities, simplifying the
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New Zealand introduces the digital services tax bill into the Parliament
On 31 August 2023, the New Zealand Government introduced the Digital Services Tax (DST) Bill into the Parliament. The Bill would allow the Government to impose, at an appropriate time, a tax on gross revenues of large multinational entities with
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Vietnam: BEPS MLI enters into force
On 1 September 2023, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Vietnam. Regarding the tax treaties covered by the Multilateral Instrument (MLI)
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Greece enacts DAC7
On 7 September 2023, Greece published Law 5047/2023 in the Official Gazette, which transposes EU Council Directive No. 2021/514 (DAC7) into Greece law to implement new rules on the exchange of information on income generated through digital
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Papua New Guinea deposits its instrument for the ratification of BEPS MLI
On 7 September 2023, the OECD published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, Papua New Guinea
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Sri Lanka: IRD releases latest tax return forms for AY 2022-23
On 15 September 2023, the Sri Lanka Inland Revenue department (IRD) released the income tax return forms for the assessment year (AY) 2022-23. The returns include: Income tax return for individuals (Form ASMT IIT 001 E). Income tax return
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Greece: AADE extends deadlines for income tax returns for the tax year 2022
On 5 September 2023, the Greek Public Revenue Authority (AADE) issued Decision A.1131, extending the tax return deadline for individuals and businesses in areas affected by the wildfires of August 2023. This includes extending the deadline for
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United Kingdom: HMRC updates APA guidance
The HMRC has recently updated its guidance (INTM 422000 et seq) on Advance Pricing Agreements (APAs). The updated guidance provides more comprehensive information, particularly in terms of the formal process and HMRC's expected timeframes. These
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Poland releases notice providing clarification on TPD documentation
On 4 September 2023, the Polish Official Gazetted a notice aimed at providing comprehensive clarification regarding the regulations governing transfer pricing documentation for corporate income tax purposes. This notice encompasses several key
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