Kenya: KRA issues notice regarding the declaration of related party transactions
On 5 June 2023, the Kenya Revenue Authority (KRA) has issued a public notice regarding the declaration of related party transactions. Accordingly, taxpayers that the Income Tax - Company Return on the i-tax system has been enhanced to provide
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Spain transposes a bill into domestic law implementing DAC7
On 25 May 2023, an announcement was published in the Spanish Official State Gazette noting that a bill related to implement the EU directive on DAC7 has been enacted to transpose into domestic law. The bill aims to improve the existing tax
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Transfer Pricing Brief: June 2023
Bolivia Filing deadlines: On 28 April 2023, the Bolivian National Tax Service published a Resolution No. 102300000014 extending the corporate income tax (IUE) reporting deadline for the tax year ending 31 December 2022 to 31 May 2023. See
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Nigeria: FIRS releases new guidelines on mutual agreement procedures
On 23 May 2023, the Federal Inland Revenue Service (FIRS) of Nigeria has released Information Circular No. 2023/04 which includes new Guidelines on Mutual Agreement Procedure (MAP). The purpose of the guidelines is to provide guidance on how to
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Malaysia: IRBM gazettes APA Rules 2023
On 29 May 2023, the Malaysian Inland Revenue Board of Revenue (IRBM) published the Income Tax (Advance Pricing Arrangement) Rules 2023 ("APA Rules 2023") in their gazette with the following key changes. Taxpayers engaged in cross-border
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Malaysia: IRBM publishes transfer pricing rules 2023
On 29 May 2023, the Malaysian Inland Revenue Board of Revenue (IRBM) officially published Order No P.U. (A) 165 (TP Rules 2023) introducing a new transfer pricing documentation process effective from assessment year 2023 onwards. The main changes
See MoreSpain releases a law introducing new interest deduction limitation rules
On 25 May 2023, Spain published Law 13/2023 in the Official Gazette, which introduces new interest deduction limitation rules in line with the EU Anti-Tax Avoidance Directive (ATAD). Spain's current rules limiting interest deduction were deemed
See MoreSpain approves corporate income tax return form for tax year 2022
On 22 May 2023, Spain published an “Order HFP/523/2023 of 22 May 2023” in the Official Gazette, approving the forms and instructions for the corporate tax and Non-Resident Income Tax returns for periods starting between 1 January and 31 December
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Portugal extends corporate tax filing deadline to 6 June 2023
On 22 May 2023, the Portugal's Secretary of State for Fiscal Affairs has issued Order No. 148/2023-XXIII. This order grants a brief extension for the submission of the annual corporate tax return and payment for the year 2022. Taxpayers now have
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UAE clarifies interest deduction rules
On 23 May 2023, the United Arab Emirates (UAE) Ministry of Finance (MoF) published Decision No. 126 of 2023 on the general rules for limiting the deduction of interest for corporate tax purposes. To determine the deductible interest from taxable
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Vietnam deposits BEPS MLI ratification instrument
On 23 May 2023, Vietnam has deposited its instrument of approval for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention). This move makes Vietnam the 81st jurisdiction to
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Luxembourg gazettes law to implement DAC7
On 19 May 2023, Luxembourg published law no 8029 in the Official Gazette to implement new rules on the exchange of information on income generated through digital platforms (DAC7). The law is in accordance with the Council Directive (EU) 2021/514 of
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Albania releases a law amending transfer pricing provisions
On 23 May 2023, Vietnam has deposited its instrument of approval for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention). This move makes Vietnam the 81st jurisdiction to
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Brazil: Federal Senate approves OECD-aligned transfer pricing rules
On 10 May 2023, the Brazilian Federal Senate approved legislation addressing the new transfer pricing which was published on 29 December 2022. This approval is one of the last steps to implement a transfer pricing system in Brazil according to
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Germany approves bill on public CbC reporting directive
On 11 May 2023, the lower house of the parliament (Bundestag) approves a bill to implement EU Directive, requiring publicly disclose CbC report for qualifying Multinational Enterprises (MNEs) operating in the EU. The Public Country-by-Country
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Germany-USA CbC report exchange agreement takes effect
On 10 May 2023, Germany has announced the official entry into force of its Country-by-Country (CbC) Report exchange agreement with the United States, as published in the Official Gazette. The agreement, which became effective on 4 April 2023, marks
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OECD: Consultation Document on Transfer Pricing Issues for Bauxite
On 10 May 2023 the OECD published a consultation document with the title Determining the price of minerals: A Transfer Pricing Framework – Schedule A: Bauxite. This document follows on from the OECD’s toolkit outlining a transfer pricing
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OECD: Consultation Document on Transfer Pricing for Minerals
On 10 May 2023 the OECD published a consultation document with the title Determining the price of minerals: A Transfer Pricing Framework. This is a draft toolkit to support developing countries in combating base erosion and profit shifting relating
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