Ireland: Revenue issues guidelines on EU tax dispute resolution mechanisms
On 17 July 2023, the Irish Revenue issued eBrief No. 165/23 on European Union (EU) tax dispute resolution mechanisms. Accordingly, Tax and Duty Manual Part 35-02-10 - Guidelines on the European Union (Tax Dispute Resolution Mechanisms) Regulations
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Luxembourg: Parliament adopts bill on public CbC reporting
On 19 July 2023, the Luxembourg Parliament adopted Bill no. 8158 to implement public Country-by-Country (CbC) reporting in compliance with Directive (EU) 2021/2101. The bill conforms to the directive and sets the public reporting threshold at an
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OECD: Subject to Tax Rule
On 17 July 2023 the OECD published details of the subject to tax rule (STTR) developed by the Inclusive Framework on BEPS as part of Pillar Two of the two-pillar proposals on international tax. The STTR gives jurisdictions the right to “tax
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Morocco delays approval of Multilateral Automatic Exchange of Information Agreements
In a recent session, held on 20 July 2023, the Moroccan House of Representatives made the decision to postpone the approval of the Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (CbC MCAA), as well as
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OECD: Outcome Statement on the Two Pillar Solution
On 11 July 2023 an Outcome Statement on the two-pillar international tax solution was approved by 138 member jurisdictions of the Inclusive Framework on base erosion and profit shifting. The Outcome Statement summarises the package of deliverables
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OECD: Consultation on Amount B of Pillar One
On 17 July 2023 the Inclusive Framework issued a consultation document asking for stakeholder input on Amount B under Pillar One. Comments are invited by 1 September 2023. Amount B applies to baseline marketing and distribution activities, which
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OECD Tax Talk Outlines Progress on Two Pillar Proposals
An OECD Tax Talk held on 19 July 2023 summarised recent developments on the two-pillar international tax proposals. Pillar One – MLC The implementation of Pillar One will require a multilateral convention (MLC) to ensure that the
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Romania provides guidelines on public CbC reporting obligations
On 21 June 2023, the Romanian Government issued guidance to implement of the EU Public Country-by-Country (CbC) reporting Directive in the Official Gazette. On 1 September 2022, Romania became one of the first European Union (EU) Member States to
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Nigeria: FIRS extends the deadline for filing CIT returns for 2023
On 10 July 2023, the Executive Chairman of the FIRS, Muhammad Nami, issued a Public Notice extending the deadline for filing companies’ income tax returns and paying the related tax liabilities. The new deadline is set for 31 August 2023,
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Turkey implements corporate income tax rate hike
On 15 July 2023, the Turkish Revenue Administration published Law No. 7456 in the Official Gazette. Accordingly, the general corporate income tax rate has been raised from 20% to 25%. The corporate income tax rate for companies operating in the
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Uganda: Parliament approves digital service tax on non-resident digital service providers
On 11 July 2023, the Ugandan Parliament approved Income Tax (Amendment) Bill 2023, which introduces a 5% digital service tax (DST) on every non-resident deriving income from providing digital services in Uganda. After President's approval, the law
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Cyprus: Tax Department issues circular on back-to-back financing transactions
On 7 July 2023, the Cyprus Tax Authority released Circular 7/2023, focusing on transfer pricing for intra-group back-to-back financing transactions. The Circular specifies that starting from the tax year 2023, the Comparable Uncontrolled Price (CUP)
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Lithuania updates definition of reverse hybrid entities to comply with ATAD2
Lithuania has amended its definition of a "reverse hybrid entity" to comply with the EU Anti-Tax Avoidance Directive (ATAD2). Previously, a Lithuanian entity was considered a reverse hybrid if it was owned by a tax resident of a foreign country, and
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Cyprus: Tax department issues transfer pricing simplification measures
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 provides guidance for persons exempt from the
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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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