Iceland announces CbC reporting requirements, deadline for FY 2024
The Icelandic Directorate of Internal Revenue has issued Notice No. 1676/2024, outlining the for country-by-country (CbC) reporting requirements for multinational enterprises for the 2024 fiscal year. As per the notice, entities subject to CbC
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Kazakhstan expands transfer pricing monitoring for cross-border transactions
Kazakhstan has expanded its list of goods, works, and services subject to transfer pricing monitoring. The updated list includes new items such as coal, lignite, hydrogen, polymers, raw aluminium, iron and steel products, various grains like rice
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Lithuania updates CbC reporting rules for MNEs
Lithuania’s tax authority has revised its Country-by-Country (CbC) reporting requirements for multinational enterprises (MNEs), effective from 21 November 2024. All notifications must now be submitted electronically via the "Mano VMI"
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France updates guidelines on royalties declaration under DAC7
French tax authorities clarified that companies managing copyright royalties and inventor rights require companies to include the beneficiary's date of birth in declarations when the recipient is an individual residing in another EU Member State.
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Dominican Republic extends CbC reporting deadline
The Dominican Republic's Directorate General of Internal Revenue (DGII) issued Notice 26-2024 on 2 January 2024, extending the deadline for the submission of Country-by-Country (CbC) reports for 2023 fiscal year to 31 January 2025. The MNE
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Poland sets base and margin rates for transfer pricing
Poland has published Notice No. 1105 in the Official Gazette on 21 December 2024, setting the base interest rates and margin interest rates for transfer pricing in individual and corporate income taxes. The regulation establishes base interest
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Brazil: Revenue authority publishes updated guidance on commodities transfer pricing
Brazil’s revenue authority (Receita Federal) has issued new guidelines for Normative Instruction RFB No. 2246 of 30 December 2024, outlining rules for companies regarding the management of transfer pricing for transactions that involve commodities
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Malaysia updates transfer pricing guidelines, audit framework
Malaysia’s Inland Revenue Board (IRB) has updated transfer pricing guidelines and transfer pricing audit framework. The transfer pricing guidelines have been updated in accordance with the amendments made to section 140A, the introduction of
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Russia updates CbC reporting jurisdictions
The Russian Federal Tax Service (FTS) has updated its list of jurisdictions for automatic exchange of country-by-country (CbC) reports, effective 31 December 2024. The revised list comprises 45 states and 10 territories, compared to the previous
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Australia gazettes instrument regarding Taxation Administration (Country by Country Reporting Jurisdictions) Determination 2024
The Australian Official Gazette, on 17 December 2024, published a legislative instrument for CbC reporting jurisdictions by the Taxation Administration for the year 2024. This instrument includes the list of CbC reporting jurisdictions along with
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Korea (Rep.): National Assembly passes 2024 Tax Law Amendment Bill
The South Korean National Assembly approved the 2024 Tax Law Amendment Bill on 10 December 2024. The amendments will affect various tax regulations which include: Deferral of Crypto Gains Tax The bill introduces a two-year deferral on the
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OECD introduces new tools to simplify transfer pricing (Amount B)
The OECD has announced the launch of new tools to streamline the implementation of Amount B under Pillar One aimed at simplifying transfer pricing rules. Amount B under the Two-Pillar Solution to Address the Tax Challenges of the Digitalising
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Switzerland: SIF updates AEOI jurisdictions list, changes status of Belize
The Swiss State Secretariat for International Finance (SIF) released an updated list of jurisdictions participating in the automatic exchange of information (AEOI) on financial accounts on 17 December 2024. Recent updates include a change in
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Australia announces jurisdictions for public CbC reporting
Australia has published the Taxation Administration (Country by Country Reporting Jurisdictions) Determination 2024, listing jurisdictions for public Country-by-Country (CbC) reporting on 12 December 2024. Notably, Liechtenstein has been excluded
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US: Treasury, IRS clarify stance on OECD’s simplified transfer pricing rules
The US Treasury Department and the Internal Revenue Service (IRS) released Notice 2025-04, “Application of the Simplified and Streamlined Approach under Section 482”, on 18 December 2024, clarifying the US government’s stance on using the
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Germany: Ministry of Finance updates transfer pricing guidelines for 2024
The German Ministry of Finance published BMF Letter No. 2024/1078709 on 12 December 2024, updating the guide on transfer pricing for 2024. The new guidelines clarify key aspects of transfer pricing which includes income correction and
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Austria gazettes Pillar Two CbCR Safe Harbour Regulation
Austria’s tax authorities published a decree in the Official Gazette on the temporary CbCR Safe Harbor (CbCR Safe Harbor Regulation) under the Minimum Taxation Act (“MinBestG”) on 5 December 2024. The MinBestG, which came into force on 31
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Australia updates guidance on public CbC reporting
The Australian Taxation Office (ATO) has revised its guidance on the public country-by-country (CbC) reporting regime focusing on public CbC parent registration requirements on 11 December 2024. Australia’s public CbC reporting is a reporting
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