Kenya: Tax measures in finance act 2023
On 3 July 2023, the Kenya Revenue Authority published the Finance Act 2023, following its presidential assent on 26 June 2023. The act includes the following notable provisions related to corporate income taxation. Digital assets
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Canada plans to enact DST in 2024
On 12 July 2023, Canadian Deputy Prime Minister and Minister of Finance said “two years ago, we agreed to pause the implementation of our own Digital Services Tax (DST), in order to give time and space for negotiations on Pillar One. But we were
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UK amends CbC notification Requirement
On 5 July 2023, the House of Commons in the United Kingdom (UK) made a significant decision by accepting Statutory Instrument No. 752/2023 to amend tax regulations on BEPS country-by-country (CbC) notification requirement. The UK government has
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Ireland: Revenue issues guidance for platform operators under DAC7
On 5 July 2023, the Irish Revenue issued eBrief No. 155/23, which provides guidance for platform operators for the exchange of information on income generated through digital platforms (DAC7). Council Directive 2011/16/EU (DAC) provides for the
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Colombia: Ministry of Finance issues draft decree on significant economic presence rule
On 30 June 2023, the Colombian Ministry of Finance issued a draft decree on the significant economic presence (SEP) rule as a part of Law 2277 of 2022 (tax reform law). The SEP rule was introduced in the context of digital services taxation. The SEP
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Luxembourg: Tax Authority updates FAQs on DAC6
On 30 June 2023, the Luxembourg Tax Authority updated the frequently asked questions (FAQs) concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). The latest update clarifies the following measures:
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Australia: New legislation proposes amendments to interest limitation rule
Legislation has been introduced in Parliament, suggesting amendment to the interest limitation or thin capitalization rules, which is closely align with the exposure draft legislation. If approved, these rules will be effective for income years
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US: IRS publishes practice units on interest expense limitations
On 16 May 2023, the IRS Large Business and International (LB&I) division issued two practice units in relation to interest expense limitations for related party loans. Interest Expense Limitation on Related Foreign Party Loans Under IRC
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Transfer Pricing Brief: July 2023
Brazil Scope of transfer pricing rules: On 14 June 2023, the president signed the Law No. 14,596 adopting Provisional Measure No. 1,152, which enacts significant changes to the Brazilian transfer pricing system that is aligned with the
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Hong Kong: IRD issues circular letter extending due date for D code returns
On 29 June 2023, the Inland Revenue Department (IRD) published a Circular Letter announcing an extension of the deadline for “D” code profit tax returns. In the letter, IRD explains that given the real difficulties faced by businesses and
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Mexico: BEPS MLI enters into force
On 3 July 2023, 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, MLI entered into force for
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Germany passes law for public Country-by-Country reporting
On 21 June 2023, Germany released the Law introducing Public Country-by-Country (CbC) reporting. This legislation is in accordance with Directive (EU) 2021/2101 and is applicable to multinational and high-revenue companies, whether related or
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Lithuania: CbC reporting directive converted into domestic law
On 15 June 2023, Lithuania has published a law which transposed the EU public CbC reporting directive into domestic law. This requirement is applicable to companies and groups engaged in business activities across a minimum of two jurisdictions,
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India: CBDT issues notification to set arm’s-length variation for 2023-2024
On 26 June 2023, the Indian Central Board of Direct Taxes (CBDT) has issued Notification No. 46/2023, setting arm's-length pricing variation limits for the 2023-24 assessment year. The limits are 1 percent for wholesale trading and 3 percent for
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Greece implements timelines and guidelines for exchange of tax information requests
On 21 June 2023, Greece has issued a circular outlining a comprehensive framework for the exchange of information, streamlining the process and setting specific timelines. The circular encompasses various mechanisms, including bilateral tax
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Germany: BMF issues updated transfer pricing guidelines
On 6 June 2023, the German Federal Ministry of Finance (BMF) has published updated transfer pricing administrative guidelines. The guidelines focus on two main areas: The application of the arm's length principle in accordance with the OECD
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Kenya: President signs the finance bill 2023
On 26 June 2023, the Kenyan president signed the finance bill 2023. The bill was published on 28th April 2023 and tabled in Parliament for the first reading on 4 th May 2023. The Parliament passed the bill on 14 June 2023. Tax proposals under the
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France : Tax Authority issues updated guidelines on scope of digital services tax
On 21 June 2023, the French tax authority issued updated guidelines clarifying the scope of the digital services tax (DST). The guidelines, reflected in administrative documents BOI-TCA-TSN-10-10-10 and BOI-TCA-TSN-10-10-20, are in response to the
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