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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France endorses public CbC reporting law
On 21 June 2023, France officially released Ordinance No. 2023-483, which mandates the public disclosure of CbC (Country-by-Country) reporting information. The ordinance was officially released in the French Official Journal. As per the European
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On 23 June 2023, the Australian government declared that it has decided to delay the implementation of public country-by-country (CbC) reporting requirement to 1 July 2024 considering feedback from stakeholders. The focus of stakeholder feedback
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Denmark: DTA extends filing deadlines for corporate tax returns and transfer pricing documentation
On 21 June 2023, the Danish Tax Agency (DTA) declared an extension of the deadline for submitting annual corporate income tax returns. The original deadline of 30 June 2023, has been postponed by eight weeks to 25 August 2023. The extension is a
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Panama extends deadline for transfer pricing return
On 26 June 2023, the Panamanian tax authority issued Resolution No. 201-5949, that announced an extension of the deadline for calendar year taxpayers to file transfer pricing return (Form 930) for fiscal year (FY) 2022. The original deadline of 30
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