Malta: CFR issued guidelines on the reporting obligations of DAC7
On 23 June 2023, the Maltese Commissioner for Revenue (CFR) published a set of guidelines in relation to the reporting obligations of Digital Platform Operators (DAC7). The DAC7 requirements come into effect on 1 January 2023 into Maltese domestic
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Ireland implements public country-by-country reporting directive
On 22 June 2023, the Irish Minister for Enterprise, Trade and Employment signed the European Union (Disclosure of income tax information by certain undertakings and branches) Regulations 2023 regarding the implementation of public country-by-country
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Uganda: Minister of Finance presents Budget for 2023/2024 to the Parliament
On June 15, 2023, the Ugandan Minister of Finance, Planning, and Economic Development, Mr. Matia Kasaija, presented the budget for financial year 2023/2024 to the Parliament. On that day, Income Tax (Amendment) Bill 2023 was also passed which was
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Brazil: President signs OECD-aligned transfer pricing rules
On 14 June 2023, the president Luiz Inácio Lula da Silva 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 guidelines provided by the
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Chile extends deadline for transfer pricing returns
On 20 June 2023, the Chilean tax authority (SII) issued Resolution No. 70 that provides an extension of three months to taxpayers who were required to submit their transfer pricing returns between 1 July 2023 and 30 September 2023. The extension
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Estonia: Parliament approves law to increase income tax rates
On 19 June 2023, the Estonian Parliament approved Income Tax Act and Defense Service Act Amendment Act 148 SE which increases both the personal income tax and corporate income tax rates by 2 percentage points to reach 22% from 20%. Also, the income
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Luxembourg clarifies registration and declaration requirements for platform operators under DAC7
On 12 June 2023, the Luxembourg Tax Authority clarified registration and declaration requirements for platform operators for the exchange of information on income generated through digital platforms (DAC7). Platform operators must register with
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UK: Consultation on Changes to Transfer Pricing Rules
On 19 June 2023 the UK government launched a consultation on potential reforms to the UK legislation on transfer pricing, permanent establishments, and diverted profits tax. Transfer Pricing - provision Currently section 147 TIOPA refers to a
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Bahrain plans to introduce corporate income tax
On 24 May 2023, the Bahraini Minister of Finance and National Economy, Mr. Shaikh Salman bin Khalifa Al-Khalifa announced in the parliament that Bahrain is planning to introduce corporate income tax in line with OECD's Pillar Two global minimum tax
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Slovenia adapts tax procedures Act to implement DAC7 regulations
Slovenia has recently introduced amendments to its tax procedures Act in order to implement the provisions of DAC7 (Council Directive EU/2021/514). This directive, adopted on 22 March 2021, seeks to enhance the exchange of information regarding
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Luxembourg: Tax Authority publishes guidance on reverse hybrid rules
On 9 June 2023, the Luxembourg Tax Authority published Circular L.I.R. n° 168quater providing guidance on reverse hybrid mismatch regulations. The Circular aims to provide further clarity on various aspects, including the tax classification of
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UK: Second Reading of Spring Finance Bill 2023
On 13 June 2023 the UK government published the Tax Information and Impact Notes for government amendments at the report stage of the Spring Finance Bill 2023. The Bill includes the following measures: Multinational Top-up tax: UK adoption of
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Canada releases consultation paper on reforming transfer pricing rules
On 6 June 2023, the Canadian Department of Finance issued a consultation paper on reforming and enhancing Transfer Pricing Rules. Budget 2021 announced the government’s intention to consult on Canada’s transfer pricing rules with a view of
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France introduces strict measures to combat international tax fraud
On 5 May 2023, French Minister for public accounts unveils anti-fraud measures targeting international tax and customs activities. Key elements of these measures include lowering the annual turnover threshold that triggers the requirement for
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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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