Germany gazettes Law regarding CbC reports exchange agreement with US
On 15 March 2023, the official gazette of Germany published the Law regarding the ratification of the agreement with the United States for exchanging Country-by-Country (CbC) Reports, which agreement signed on 14 August 2020. The law enters into
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Lithuania publishes draft law to transpose public CbC reporting
On 7 March 2023, the government of Lithuania issued a draft law to transpose the EU Public Country-by-Country (CbC) Reporting Directive into domestic law. According to the Directive, the upcoming legislation will mandate multinational corporations
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OECD: Peer Review Report on the Prevention of Treaty Shopping
On 21 March 2023 the OECD released the latest peer review results following assessment of the actions taken by each country to prevent tax treaty shopping under BEPS Action 6. The Fifth Peer Review Report on Treaty Shopping assesses the
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Azerbaijan plans to sign the BEPS MLI
On 17 March 2023, the Ministry of Taxes of Azerbaijan released a statement regarding the implementation of obligations under BEPS activities. According to the statement, Azerbaijan plans to sign the Multilateral Convention to Implement Tax Treaty
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Australia releases exposure draft bill on new thin cap rules
On 16 March 2023, the Australian Treasury issued the Exposure Draft on the earnings before interest, taxes, depreciation, and amortization interest limitation rules (EBITDA). Consultation closes on 13 April 2023. The proposal to change the
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Mexico deposits ratification instrument for BEPS MLI
On 15 March 2023, Mexico deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI). The Convention will enter into force in relation to Mexico on 1 July 2023.
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Cyprus: Tax department issues additional FAQs on TPD rules
On 14 March 2023, the Tax Department of Cyprus has issued three additional questions to its Frequently Asked Questions (FAQs) section, with respect to transfer pricing. The additional questions are summarized below: How is the EUR 750,000
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Indonesia: DGT confirms to implement pillar two GloBE rules from 2024
The Director of International Taxation of the Directorate General of Taxes has confirmed that Indonesia is planning to implement the Pillar Two GloBE Rules from 2024. On 1-3 March 2023, the Ministry of Finance, Republic of Indonesia including
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Sweden: Tax Agency declares new e-Service for digital platform operators
The Swedish Tax Agency has made an announcement that a newly launched e-service portal is now accessible for the registration process of platform operators. Platform operators covered by the rules must register by 30 June 2023 at the latest.
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Malta: CFR provides guidelines on DAC6 notification obligations for intermediaries
On 8 March 2023, the Maltese Commissioner for Revenue (CFR) provides guidelines in relation to the waiver from filing information in respect of a reportable cross-border arrangement (DAC6). Following the CJEU decision on 8 December 2022, Maltese
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Croatia enacts DAC7
On 8 March 2023, the Croatian Official Gazette published Regulation No. 448, which implements the European Union Council Directive on the mandatory automatic exchange of financial account information (AEOI) for digital platform operators
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Malta: CFR extends electronic filing deadline of CIT returns for 2023
On 8 March 2023, the Maltese Commissioner for Revenue (CFR) notified that the deadlines for the electronic filing of corporate income tax (CIT) have been extended as follows: Financial Year Ending Manual Return Deadline Electronic
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Angola becomes a member of the global forum for transparency and exchange of information
On 8 March 2023, the Organization for Economic Co-operation and Development (OECD) announced that Angola has joined the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum). Like all other members, Angola will
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Germany gazettes amendment regulation for exchange of CbC reports
On 27 February 2023, the German official Gazette issued a regulation amending the list of jurisdictions participating under the Multilateral Competent Authority Agreement (MCAA) on the exchange of country-by-country (CbC) reports. The law came into
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New Zealand: Finance and Expenditure Committee proposes additional measures to the taxation bill
On 2 March 2023, the Finance and Expenditure Select Committee submitted a report to Parliament on the Taxation (Annual Rates for 2022–23, Platform Economy, and Remedial Matters) Bill (No 2), introduced on 8 September 2022. The committee has
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Greece: Public Revenue Authority publishes frequently asked question on CbC Report
On 24 February 2023, the Public Revenue Authority released frequently asked question (FAQ) document in English providing the elaborate description of country-by-country (CbC) reporting, related OECD Country-by-Country reporting guidelines and
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Hong Kong deposits BEPS MLI ratification instrument
On 21 February 2023, Hong Kong 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). Pursuant to Article 35(7)(b) of the
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Brazil issues normative instruction establishing new transfer pricing regulations for 2023
On 24 February 2023, the Brazilian Federal Revenue Office published the Normative Instruction No. 2.132 which establishes the regulation of the taxpayer's choice to apply the new transfer pricing rules according to Provisional Measure (PM) No.
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