Norway: MoF launches public consultation proposing to change interest limitation rules
On 12 April 2023, the Norwegian Ministry of Finance launched a public consultation providing a proposal to change the interest limitation rules, which generally limit the deduction of interest expenses for related parties that exceed 25% of EBITDA
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South Africa issues interpretation note on definition of associated enterprise
On 17 April 2023, the South African Revenue Service (SARS) published an interpretation note 128 on the definition of “associated enterprise”. This note provides guidance on the interpretation and application of the definition of “associated
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Hong Kong: IRD issues circular letter extending due date for N code returns
On 14 April 2023, the Inland Revenue Department (IRD) of Hong Kong issued a Circular Letter providing an extension of due date for N code returns. Recognising the genuine difficulties being experienced by businesses and practitioners in their
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Malta: CFR updates FAQs on DAC6
On 13 April 2023, the Maltese Commissioner for Revenue (CFR) updated “frequently asked questions” (FAQs) on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements (DAC6). Accordingly, the following questions
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Algeria: DGI extends the deadline for 2022 annual tax returns
On 12 April 2023, the Algerian Directorate General of Taxes (DGI) issued a communiqué prolonging the deadline for filing tax returns for 2022. Accordingly, the deadline for the 2022 tax return is extended to 31 May 2023 (normally due by 30 April of
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Saudi Arabia: ZATCA approves amendment to the TP Bylaws
On 20 March 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) approved Decision No. 8-2-23 to amend the Transfer Pricing (TP) Bylaws. The approved amendments to the TP Bylaws in Saudi Arabia will expand the scope of the provisions to
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Thailand approves MCAA for automatic exchange of financial account information
On 30 March 2023, Thailand issued a royal decree to implement the Multilateral Competent Authority Agreement (MCAA) for the Automatic Exchange of Financial Account Information. The MCAA was signed by Thailand in July 2022 and allows for information
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Australia releases draft legislation on public CbC reporting requirement
On 6 April 2023, the Australian Treasury Department issued draft legislation outlining the implementation of public country-by-country (CbC) reporting requirements for specific tax-related information to be disclosed by multinational enterprises
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Uganda proposes digital service tax through income tax amendment bill 2023
On 30 March 2023, the Minister of Finance, Planning and Economic Development of Uganda issued Income Tax (Amendment) Bill 2023. Under the bill, Uganda proposes a 5% digital service tax (DST) on every non-resident person deriving income from
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Italy enacts DAC7
On 25 March 2023, Italy published Legislative Decree No. 32/2023 in the Official Gazette for the implementation of EU Council Directive 2021/514 into domestic law on the mandatory automatic exchange of financial account information for digital
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Poland: MoF publishes guideline on transfer pricing method
On 24 March 2023, the Polish Ministry of Finance published guidance clarifying the application of the resale price method to determine the arm's length value of transactions between related parties. The guidance focuses on practical aspects of using
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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
See MoreHong 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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