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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Sri Lanka: IRD publishes MAP guidelines
On 8 May 2023, the Sri Lanka Inland Revenue Department (IRD) has published Mutual Agreement Procedure (MAP) guidelines. The guidelines provide several key aspects related to Mutual Agreement Procedure (MAP) requests in Sri Lanka. The guidelines
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UAE: MoF issues decision on TP documentation requirements
On 11 May 2023, the United Arab Emirates (UAE) Ministry of Finance (MoF) issued Ministerial Decision No. 97 of 2023 on the requirements for maintaining transfer pricing (TP) documentation. Federal Decree Law No (47) of 2023 on the Taxation of
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Australia: Federal Budget for FY 2023-24
On 9 May 2023, Mr. Jim Chalmers, the Australian Treasurer handed down Federal Budget for FY 2023-24, with some proposed changes to tax and superannuation laws. Many of the measures announced are subject to receiving royal assent and therefore not
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Lithuania considers draft order for public CbC Reporting
The Lithuanian parliament (Seimas) is currently considering draft Order 23-4588, which aims to introduce public Country-by-Country (CbC) reporting obligations in line with Directive (EU) 2021/2101. The draft Order specifies the required content of
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Bolivia grants extension for submitting corporate income tax reporting requirements
On 28 April 2022, 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 for (i) financial statements; (ii) annual
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Luxembourg: Parliament approves law to implement DAC7
On 3 May 2023, the Luxembourg Parliament approved law no. 8029 to implement new rules on the exchange of information on income generated through digital platforms (DAC7) in accordance with the Council Directive (EU) 2021/514 of 22 March 2021. The
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US: IRS releases interim guidance on review and acceptance of APA submissions
On 25 April 2023, the Internal Revenue Service (IRS) published a memorandum providing guidance to employees of the Treaty and Transfer Pricing Operations (TTPO) practice area in the Large Business and International Division (LB&I) with respect
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Belgium declares e-Filing services for CIT returns
On 28 April 2023, the Belgian Federal Public Service Finance made an official announcement regarding the launch of the Biztax e-service. This digital platform is aimed at facilitating the submission of corporate income tax (CIT) returns for the
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Transfer Pricing Brief: May 2023
Algeria Filing deadlines: The Algerian Directorate General of Taxes (DGI) has extended the deadline for filing corporate tax returns to 31 May 2023 for the tax year 2022. See the story in Regfollower Brazil Scope of transfer pricing
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Kenya: Transfer pricing tax measures in Finance Bill 2023
On 28 April 2023, the Cabinet Secretary of the Kenya Ministry of Finance submitted the Finance Bill 2023 (the Bill) to Parliament, which provides the following tax measures related to transfer pricing. The bill proposes to prohibit taxpayers from
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The Internal Revenue Service (IRS) Large Business and International (LB&I) division released a memorandum providing guidance to employees of the Treaty and Transfer Pricing Operations (TTPO) practice area in the Large Business and International
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India: Supreme Court decides high courts responsible for adjudicating transfer pricing cases
On 19 April 2023, the Indian Supreme Court published a decision on whether High Courts should hear appeals challenging the findings of the Income Tax Appellate Tribunal on transfer pricing issues. The judgment pertains to cases where appeals
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Turkey extends several deadlines for tax return and payment
On 25 April 2023, the Turkish Revenue Administration announced the extension of several deadlines for tax returns and payment. Accordingly, the corporate tax return and payment deadline for the accounting period 2022 has been extended to May 5 2023
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Chile: Tax authority clarifies time limits for MAP requests
On 19 April 2023, Circular No. 19 was released by the Chilean tax authority. This circular modifies Circular No. 13, which was published on 18 March 2022, which provides guidance on the Mutual Agreement Procedures (MAP) under Chile’s tax treaties.
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Luxembourg: Government submits draft bill on transfer pricing and general tax procedures
On 28 March 2023, the Luxembourg government submitted Bill No. 8186 to the Parliament. The bill includes changes in advance pricing arrangement (APA), mutual agreement procedure (MAP), compliance with transfer pricing documentation requirements, and
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