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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UK: HMRC announces new reporting regulations for digital platform operators (DAC7)
On 20 July 2023, the United Kingdom’s HMRC issued a policy paper outlining a comprehensive plan to establish reporting regulations for digital platform operators operating in the United Kingdom (UK). This initiative, which aligns with the OECD
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Ukraine ensures technical capacity for information exchange on CRS and CbCR
On 17 August 2023, Ukraine announced that the development of software for the State Tax Service of Ukraine has been completed, which will ensure the international automatic exchange of information under the Common Reporting Standard (CRS) and the
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Israel releases Guidance on MAP and APA procedures
On 17 August 2023, the Israel Tax Authority (ITA) released Tax Circular No. 1/2023, which provides guidance for mutual agreement procedure (MAP), and bilateral advance pricing agreement (APA) requests. The new circular replaces the guidance of
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Canada updates electronic filing requirements for business entities
On 16 August 2023, the Canada Revenue Agency (CRA) announced that businesses filing six or more information returns must file them electronically to avoid penalties. Recent legislation has amended mandatory electronic filing thresholds.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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,
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