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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Kenya: KRA publishes draft transfer pricing rules 2023
On 4 September 2023, the Kenya Revenue Authority (KRA) published draft income tax (Transfer Pricing) rules 2023 for public comment. The income tax rules are designed to harmonize with the provisions of the Finance Act 2022, which introduced
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Denmark updates arbitration position profile for MLI
On 7 September 2023, the Organization for Economic Cooperation and Development (OECD) issued an updated arbitration position profile for Denmark within the context of Part VI of the Multilateral Convention for the Implementation of Measures to
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US: IRS announces that businesses of cash payment over $10000 must electronically file from 2024
On 30 August 2023, the U.S. Internal Revenue Service (IRS) announced that starting Jan. 1, 2024, businesses are required to electronically file (e-file) Form 8300, Report of Cash Payments Over $10,000, instead of filing a paper return. This new
See MoreG20 Leaders’ Declaration
The Declaration issued by the G20 leaders at their meeting on 9 and 10 September 2023 included the following points: Global Economic Situation The Declaration noted the recent global crises that have posed challenges to long-term growth and
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Germany: Government releases revised draft bill on corporate tax reform
On 30 August 2023, the German government released a revised version of the Growth Opportunities Act, originally proposed by the German Ministry of Finance in mid-July. This release marks the commencement of the formal legislative procedure with
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Dominican Republic signs MCAA for the exchange of CbCR
On 5 September 2023, the OECD updated its list of signatories to the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country Reports (CbCR), showing that the Dominican Republic joined the agreement on 6 July 2023.
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OECD: Report to the G20 leaders meeting of September 2023
The tax report by the OECD Secretary General to the meeting of G20 leaders on 9 to 10 September 2023 outlines the latest international tax developments in international tax reform, including the work on the two-pillar international tax plan;
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Morocco releases latest CbC reporting guidance
The Moroccan General Directorate of Taxation (DGI) has recently released latest Country-by-Country (CbC) reporting guidance. Morocco implemented CbC reporting obligations starting from 1 January 2021, in accordance with the Finance Law for 2020.
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Transfer Pricing Brief: September 2023
Australia Audit risk assessment: The Australian National Audit Office (ANAO) is conducting a performance audit to evaluate the efficiency of the Australian Taxation Office’s (ATO) transfer pricing (TP) management concerning loans between
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Malta: CFR updates guidelines on the reporting obligations of DAC7
On 31 August 2023, the Maltese Commissioner for Revenue (CFR) updated guidelines in relation to the reporting obligations of Digital Platform Operators (DAC7). The DAC7 requirements come into effect on 1 January 2023 into Maltese domestic law. The
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Luxembourg implements public CbC reporting
On 22 August 2023, Luxembourg published Law of 15 August 2023 in the Official Gazette implementing public Country-by-Country (CbC) reporting in compliance with Directive (EU) 2021/2101. The Law conforms to the directive and sets the public
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India: CBDT extends transfer pricing Safe Harbor Rules
On 9 August 2023, the Central Board of Direct Taxes (CBDT) issued a Notification No. 58/2023, to extend the applicability of the transfer pricing safe harbor rules. The extension applies for the financial year 2022-23 and 2023-24 assessment years.
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Anguilla suspends exchange of tax information with Russia and Belarus
On 21 August 2023, the Government of Anguilla announced the suspension of exchanges and the sharing of tax information with Russia and Belarus in solidarity with the United Kingdom (UK) Government. Tax information is exchanged as part of a
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Portugal implements CbC reporting requirements
On 23 August 2023, the Portuguese government published Decree-Law No. 73/2023 in the Official Gazette, which establishes the requirements for public country-by-country (CbC) reporting by multinational enterprises (MNEs). The new rules on public
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UK updates transfer pricing documentation requirements
The United Kingdom (UK) has published the Transfer Pricing Records Regulations 2023, which updated transfer pricing documentation requirements by introducing Local file and Master file requirements. The UK has officially updated its transfer
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IMF: International Tax Spillovers and Tangible Investments
On 4 August 2023 an IMF working paper was published with the title International Tax Spillovers and Tangible Investments, with Implications for the Global Minimum Tax, authored by Michael Keen, Li Liu and Hayley Pallan. The paper assembles new data
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UN: Report of the Secretary General on Promoting Inclusive Tax Cooperation
An advance unedited report released by the UN Secretary General on 8 August 2023 considered the Promotion of inclusive and effective international tax cooperation at the United Nations. A final version of the report is to be released in time for the
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