Transfer Pricing Brief: March 2023
Cyprus Documentation-Local file/Master file: On 10 February 2023, the Cyprus Tax Department published a set of Frequently Asked Questions (FAQs) aiming to clarify certain provisions of the new transfer pricing rules approved in June 2022 with
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OECD Tax Talk Outlines Latest Developments
On 27 February 2023 the OECD gave an update of recent developments in their tax work. G20 Chair’s summary The G20 Chair’s summary following the meeting of G20 finance ministers and central bank governors confirmed that the G20 remains
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OECD Report to the February 2023 Meeting of G20 Finance Ministers
On 24 February 2023 the OECD published its report to the February 2023 meeting of the G20 Finance Ministers and Central Bank Governors. Inclusive Framework The report notes that the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework)
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Luxembourg: Government presents a draft bill to the Parliament on public CbC reporting
On 24 February 2023, the Luxembourg government presented Bill no. 8158 to the Parliament 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
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Italy: Council of Ministers approves decree to implement DAC7
On 23 February 2023, Italian Council of Ministers approved the legislative decree to implement new rules on the exchange of information on income generated through digital platforms (DAC7). DAC7 rules requires digital platform operators to
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Turkey extends tax compliance deadline for additional areas due to earthquakes
On 16 February 2023, the Turkish Revenue Administration further announced emergency tax measures for the taxpayers located in Elazig due to earthquakes. Moreover, the Revenue Administration announced the emergency tax measures on 21 Feb 2023 for the
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Cyprus: Tax department issues FAQs on new transfer pricing legislation
On 10 February 2023, the Cyprus Tax Department published a set of Frequently Asked Questions (FAQs) aiming to clarify certain provisions of the new transfer pricing rules approved in June 2022 with effect from 1 January 2022, including Local File
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Sweden sign MCAA to exchange information with respect to income earned on digital platforms
On 2 February 2023, Sweden signed the multilateral competent authority agreement on the automatic exchange of information on income derived through digital platforms, according to an update published by OECD on 15 February 2023. The DPI-MCAA has
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Malta: CFR extends DAC6 annual notification deadline for non-disclosing intermediaries
On 17 February 2023, the Maltese Commissioner for Revenue (CFR) notified that the deadline for annual notification of cross-border arrangements (DAC6) by non-disclosing intermediaries is being extended. Accordingly, non-disclosing intermediaries
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Finland: Tax agency issues guidance on application of OECD guidelines for domestic TP rules
On 8 February 2023, the Finnish tax administration issued guidance No.VH/5942/00.01.00/2022 on the application of OECD transfer pricing guidelines to domestic transfer pricing rules. The purpose of the guidance is also to summarize the effects of
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Poland: MoF extends the filing deadline for CIT to 30 June 2023
The Polish Ministry of Finance has announced a proposal to extend the filing and payment deadline for corporate income tax returns by three months, until 30 June 2023. Last year, due to the COVID-19 pandemic, the deadline for filing forms CIT-8,
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Germany: Lower house of parliament adopts CbC exchange agreement with USA
On 9 February 2023, the German lower house of parliament (Bundestag) has approved a law to ratify the pending agreement with the USA on the exchange of CbC reports. The agreement was signed on 14 August 2020. The agreement will enter into force when
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Sweden: Ministry of Justice propose a bill implementing public CbC reporting
On 9 February 2023, the Swedish Ministry of Justice published a press release of proposal implementing the EU directive 2021/221 to disclose publicly certain information on a country-by-country (CbC) regarding multinational companies. According to
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Switzerland publishes safe harbor interest rates for 2023
The Swiss Federal Tax Administration (SFTA) recently released Circular Letter No. 203 and Circular Letter No. 204 on 7 and 8 February 2023, respectively. These circulars provide safe harbor interest rates for intercompany loans and advances in Swiss
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UK: HMRC publishes guidance on ADR procedure
On 1 February 2023, UK HMRC published Alternative Dispute Resolution (ADR) Guidance with details of an alternative dispute resolution procedure. ADR in HMRC is a flexible process in which an impartial and neutral HMRC mediator actively assists
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Turkey extends tax compliance deadline for certain areas due to earthquakes
On 8 February 2023, the Turkish Revenue Administration announced an emergency tax measures for certain areas due to earthquakes. Accordingly, taxpayers located in Adana, Adiyaman, Diyarbakir, Gaziantep, Hatay, Kahramanmaras, Kilis, Malatya,
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US: Tax court approves agreement resolving APA cancellation case
On 3 February 2023, the US Tax Court issued a rule approving an agreement between Eaton Corporation and the IRS to adjust Eaton's tax bill for 2005 and 2006 to USD 8.8 million. The proposal stems from lengthy litigation in both the Tax Court and
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Romania enacts DAC7
On 31 January 2023, Romania published Ordinance No. 16/2023 in the Official Gazette, which transposes EU Council Directive No. 2021/514 (DAC7) into Romanian law to implement new rules on the exchange of information on income generated through
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