Brazil: Lower House passes transfer pricing reform measure
On 30 March 2023, the Brazilian Lower House of Congress adopted Measure No. 1,152 to overhaul its transfer pricing system that was introduced on 29 December 2022. In addition to introducing the arm's length principle into the Brazilian transfer
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US and Germany sign CAA regarding CbC exchange arrangement
On 24 March 2023, US and Germany signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. The Competent Authorities desire to conclude this Arrangement on the exchange of CbC Reports based on domestic reporting and
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Transfer Pricing Brief: April 2023
Australia Restriction on interest deduction: 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
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Hong Kong: IRD issues profits tax, property tax and employer’s returns for 2022-23
On 3 April 2023, the Inland Revenue Department issued about 220 000 profits tax returns, 120 000 property tax returns and 310 000 employer's returns for the year of assessment 2022-23. About 2.4 million of tax returns for individuals will be issued
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Costa Rica extends filing deadline for inactive entities
On 29 March 2023, Costa Rica issued Resolution No. MH-DGT-RES-007-2023 providing an extension of filing annual informative return for inactive entities. Usually, inactive entities are required to file their informative return by 30 April of each
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Serbia: MoF adopts arm’s length interest rates for 2023
On 29 March 2023, the Serbian Ministry of Finance has approved the rulebook on arm’s length interest rates for 2023. The rulebook will be effective from 6 April 2023. Interest rates in accordance with “arm’s-length” principle that applies
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UK enacts Mandatory Disclosure Rules
The OECD Model Mandatory Disclosure Rules (MDR), which require the disclosure of cross-border tax avoidance arrangements, enacted in the UK on 28 March 2023. The MDR imposes an obligation on taxpayers and advisers to provide information to the tax
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Singapore: IRAS updates list of jurisdictions under CbC reporting
On 24 March 2023, the Inland Revenue Authority of Singapore (IRAS) updated the list of countries involved in the automatic exchange of Country-by-Country reports (CbC) under the Multilateral Competent Authority Agreement (MCAA). Israel is included
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Poland releases decree extending CIT return deadline
On 21 March 2023, the Polish Ministry of Finance published a decree extending the deadline for filing corporate income tax returns (CIT) and the related payment. According to the decree, the obligation to pay corporate income tax and to file the
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Chile launches public consultation on MAP
The Internal Revenue Service (SII) of Chile has launched a public consultation on a draft circular that aims to clarify the 3-year deadline for submitting a mutual agreement procedure (MAP) request. The SII is accepting feedback from the public
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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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