Egypt releases explanatory instructions on transfer pricing reporting obligations
On 19 September 2023, the Egyptian Tax Authority issued Explanatory Instruction No. 78 introducing mandatory transfer pricing reporting obligations for related party transactions. Accordingly, the Tax Authority has set deadlines for submitting
See More
Ukraine proposes to temporarily double the corporate income tax rate for banks
On 19 October 2023, the Ukrainian Parliament (Verkhovna Rada) passed Draft Law 9656-d in the first reading. Accordingly, Ukraine proposes to temporarily double the corporate income tax rate from 18% to 36% for banks for tax periods starting from 1
See More
Poland introduces new electronic templates to report transfer pricing
On 17 October 2023, the Polish Ministry of Finance released new electronic templates for transfer pricing reporting on its website. These templates include: Personal Income Tax Transfer Pricing Report - TPR-P(5) Corporate Income Tax
See More
Belgium releases FAQ on DAC7 obligations of digital platform operators
The Ministry of Finance in Belgium has recently released a Frequently Asked Questions (FAQ)Â addressing the obligations of digital platform operators imposed by DAC7 (Council Directive (EU) 2021/514). Under DAC7 rule, the digital platform
See MoreBelgium approves draft law on public CbC reporting
On 13 October 2023, the Belgian Council of Ministers passed the preliminary draft law for transposing the EU public country-by-country (CbC) reporting directive (2021/2101). According to the new public (CbC) rules, groups with consolidated
See More
Chile declares revised tax return deadlines for 2024
On 4 October 2023, the Chilean federal tax agency published Resolution No. 116 with revised filing deadlines of different forms for the 2024 tax year. The deadlines of forms are as follows: March 1: Forms 1811, 1822, 1834, 1891, 1900, 1902,
See More
Australia seeks feedback on amendments to interest limitation rules
On 18 October 2023, the Australian Treasury Department opened a consultation on an exposure draft bill to amend the interest limitation rules. As part of the 2022-23 Budget, an integrity measure was announced to address risks to Australia’s
See More
US and Israel sign agreement on the exchange of CbC reports
The Internal Revenue Service (IRS) of the United States has released the competent authority arrangement concerning exchanging Country-by-Country (CbC) Reports with Israel. As per the IRS CbC Reporting Jurisdiction Status Table, this arrangement
See More
Brazil releases normative instruction for its new transfer pricing rules
On 28 September 2023, Brazil published Normative Instruction Nº 2,161 (IN 2,161/23) that governs Brazil’s recently established new transfer pricing law. The new legislation explicitly adopts the arm's length principle into the Brazilian legal
See More
Slovenia: Tax agency declares CbC reporting deadline
On 10 October 2023, the Slovenian Tax Agency (Financial Administration) declared that country-by-country (CbC) reports for the fiscal year ending on 31 December 2022 , submission is a mandatory requirement by 31 December 2023. Taxpayers must submit
See More
El Salvador: MoF extends tax amnesty up to 30 September 2023
The Ministry of Finance of El Salvador has introduced a new tax amnesty regime allowing taxpayers to settle their outstanding tax and customs obligations up to 30 September 2023. The El Salvador tax authorities will waive all incurring interest,
See More
Cyprus announces expected effective date of CbC exchange agreement with the US
On 5 October 2023, the Cyprus Tax Department issued a notice regarding the anticipated implementation date of the agreement for the exchange of Country-by-Country (CbC) reports with the United States alongside the local filing obligations. The
See More
OECD: Report to the Meeting of G20 Finance Ministers and Central Bank Governors
The OECD Secretary General’s report to the meeting of G20 Finance Ministers and Central Bank Governors covered the following issues: Two-Pillar International Tax Package The Inclusive Framework has now released the text of the Multilateral
See More
OECD: Multilateral Convention in Relation to Amount A of Pillar One
On 11 October 2023 the OECD’s Inclusive Framework released the finalised text of a multilateral convention in relation to Amount A of Pillar One, to co-ordinate the implementation of the reallocation of taxing rights to market jurisdictions,
See More
France: FTA publishes update guidelines on DAC6
On 13 September 2023, the French tax authorities (FTA) revised their DAC 6 administrative guidelines in order to provide further clarification on hallmark D.1.b. This particular hallmark relates to the automatic exchange of information and
See More
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
See More
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
See More
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
See More