Canada releases revised draft DST Act for public comments
On 4 August 2023, the Department of Finance Canada published a revised draft of the Digital Services Tax (DST) Act for public consultation. These legislative proposals would implement the Digital Services Tax Act. The Act would impose a tax
See More
France updates list of exempted countries for CbC report local filing requirements
On 13 August 2023, Government published the Decree which amends the Order 6 July 2017 pursuant to II of Article 223 quinquies C of the General Tax Code. The new Decree updates the the list of country exemption from local filing Country-by-Country
See More
Paraguay upgrades transfer pricing documentation process
On 20 July 2023, the tax authority of Paraguay (SET) issued General Resolution No. 134 of 18 July 2023, that introduces an exceptional mechanism for the submission of the technical transfer pricing study (Estudio Técnico de Precios de Transferencia
See More
South Korea: MOEF announce tax reform proposal for 2023
On 27 July 2023, South Korea’s Ministry of Economy and Finance (MOEF) announced the tax reform proposal for 2023. The tax reform proposal includes changes in the Korean Pillar two global minimum tax rules and transfer pricing compliance
See More
Netherlands: House of Representatives adopts legislation for public CbC Reporting
On 6 July 2023, the Dutch House of Representatives passed legislation aimed at implementing the Public Country-by-Country (CbC) Reporting Directive. This move highlights the Netherlands' commitment to transparency and aligns with international
See More
South Africa publishes a draft legislation to implement APA program
On 31 July 2023, the National Treasury of South Africa proposes a draft legislation to implement advance pricing agreement (APA) program. An APA program offers taxpayers an enhanced level of assurance when engaging in significant international
See More
Australia conducting performance audit on TP management
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 related parties. The ANAO proposes to
See More
Georgia adopts rules on Mutual Agreement Procedures (MAP)
The Ministry of Finance of Georgia recently published Decree No. 258 of July 2023, which approves the rules for the Mutual Agreement Procedures (MAP) under the Tax Treaties of Georgia or the provisions of the BEPS MLI. The rules encompass various
See More
OECD: Mitigating the Risks of Illicit Financial Flows in Oil Commodity Trading
On 8 August 2023 the OECD issued policy guidance for policymakers and practitioners on managing the problem of Illicit Financial Flows (IFFs) in oil commodity trading. The Policy Guidance on Mitigating the Risks of Illicit Financial Flows in Oil
See More
Transfer Pricing Brief: August 2023
Cyprus Local file: On 6 July 2023, the Cyprus Tax Department released a new circular (6/2023) entitled “Simplification measures for persons exempt from the obligation to maintain a Cyprus local file”. The Circular clarifies that persons
See More
Spain: National Court issues rule on TP adjustment using median of arm’s length range
On 29 July 2023, the Spanish National Court issued a decision that provided clarification on the range of arm's length pricing adjustments applicable. In this case, Ferroli Spain, a Spanish manufacturer specializing in non-electric stoves,
See More
Serbia amends the law to ratify BEPS MLI
On 27 July 2023, Serbia published in the Official Gazette Decree No. 78 of July 2023, approving amendments to the Law on Ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent Base Erosion and
See More
Pakistan: FBR issues circular on finance Act changes
On 26 July 2023, the Federal Board of Revenue in Pakistan (FBR) issued Circular No. 2 of 2023, providing an explanation of the income tax amendments introduced through the Finance Act of 2023. The circular elaborates on the following
See More
Vietnam publishes notice regarding entry into force for BEPS MLI
On 28 July 2023, Vietnam gazetted the “Notice No. 12/2023/TB-LPQT of 21 June 2023” regarding entry into force for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). The MLI will be entered into force on 1
See More
Papua New Guinea signs multilateral competent authority agreement on exchange of CbC reports
On 26 July 2023, the OECD published their updated list of signatories for the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country Reports (CbCR), showing that Papua New Guinea joined the agreement on 14 March
See More
Singapore updates list of jurisdictions under MCAA-CbC
On 20 July 2023, the Inland Revenue Authority of Singapore (IRAS) updated the list of jurisdictions participating under the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports. Aruba has been
See More
Egypt publishes income tax amendment law
On 15 June 2023, the Egyptian Tax Authority published Law No. 30 of 2023 in the Official Gazette amending some provisions of the Income Tax Law No. 91 of 2005. The Law entered into force on 16 June 2023. The key amendments to the Income Tax Law are
See More
Germany released new draft guidance on anti-hybrid rules
On 14 July 2023, the German Ministry of Finance has released a draft decree outlining the application of the country's anti-hybrid rules, established in 2021 under the European Union (EU) Anti-Tax Avoidance Directive (ATAD) implementation Law. These
See More