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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Serbia amends the law to ratify BEPS MLI
On 27 July 2023, Serbia published in the Official Gazette Decree No. 78 of July 2023, approving amendments to the Law on Ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent Base Erosion and
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Pakistan: FBR issues circular on finance Act changes
On 26 July 2023, the Federal Board of Revenue in Pakistan (FBR) issued Circular No. 2 of 2023, providing an explanation of the income tax amendments introduced through the Finance Act of 2023. The circular elaborates on the following
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Vietnam publishes notice regarding entry into force for BEPS MLI
On 28 July 2023, Vietnam gazetted the “Notice No. 12/2023/TB-LPQT of 21 June 2023” regarding entry into force for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). The MLI will be entered into force on 1
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Papua New Guinea signs multilateral competent authority agreement on exchange of CbC reports
On 26 July 2023, the OECD published their updated list of signatories for the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country Reports (CbCR), showing that Papua New Guinea joined the agreement on 14 March
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Singapore updates list of jurisdictions under MCAA-CbC
On 20 July 2023, the Inland Revenue Authority of Singapore (IRAS) updated the list of jurisdictions participating under the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports. Aruba has been
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Egypt publishes income tax amendment law
On 15 June 2023, the Egyptian Tax Authority published Law No. 30 of 2023 in the Official Gazette amending some provisions of the Income Tax Law No. 91 of 2005. The Law entered into force on 16 June 2023. The key amendments to the Income Tax Law are
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Germany released new draft guidance on anti-hybrid rules
On 14 July 2023, the German Ministry of Finance has released a draft decree outlining the application of the country's anti-hybrid rules, established in 2021 under the European Union (EU) Anti-Tax Avoidance Directive (ATAD) implementation Law. These
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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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