Israel publishes a new CbC Notification form
The Israeli Tax Authority (ITA) has recently released a new Notification Form 1585 for the disclosure of information related to Country-by-country reporting (CbCR). This includes providing details on group revenues, identifying the Ultimate Parent
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UK: Transfer Pricing and Diverted Profits Tax Statistics
On 7 February 2022 HMRC published the latest set of statistics relating to transfer pricing and the diverted profits tax. The latest release contains data up to end of the 2022/22 tax year. The transfer pricing work is an important part of
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Malaysia: IRBM issues FAQs to clarify MAP guidelines
On 1 February 2023, the Inland Revenue Board of Malaysia (IRBM) has issued a list of frequently asked questions (FAQs) on the mutual agreement procedure (MAP) to provide further clarification to the 2017 MAP guidelines. In relation to the
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Jamaica: TAJ reminds tax filing deadline for the tax year 2022
On 2 February 2023, Tax Administration Jamaica (TAJ) reminded the taxpayers that the income tax filing deadline is 15 March 2023. The taxpayers are being reminded that filing their annual income tax return for the year 2022 and declaring their
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Transfer Pricing Brief: February 2023
Argentina Scope of transfer pricing rules: On 27 December 2022, Argentina’s federal tax authority (AFIP) released General Resolution No.5306/2022, establishing a new mandatory disclosure regime for certain international transactions. The
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Singapore: Ministry of Finance Gazettes Order Declaring MCAA-CbC
On 27 January 2023, the Singaporean Official Gazette issued an Order No. S 26, which declares that the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country Reports (CbC) is an international tax compliance agreement
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Spain presents DAC7 bill to parliament
On 27 January 2023, Spain submitted a bill to Parliament for implementing Council Directive (EU) 2021/514 (DAC7), which requires digital platform operators to report the revenue generated by sellers on their digital platforms and for EU Member
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Hungary: MoF publishes decree amending TP rules on transfer pricing documentation
On 28 December 2022, the Hungarian Ministry of Finance published Decree 27/2022 (XII.28) which amends the Decree 32/2017 (X.18) on the documentation requirement related to the determination of arm’s length prices. Increase threshold
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Russia updates the list of foreign states for automatic exchange of CbC reports
Recently, the Federal Tax Service of Russia published (Order No. ED-7-17/1226) a new list of foreign states and territories, with which Russia will automatically exchange Country-by-Country (CbC) reports. Accordingly, the following states are
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India: Finance Minister presents Union Budget for 2023-2024
On 1 February 2023, Ms. Nirmala Sitharaman, the Finance Minister of India presented the Union Budget for 2023-24 to the Parliament. The budget includes the following key tax proposals: Corporate tax proposals: A provision for tax treaty
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OECD: Public comments received on the design elements of Amount B under Pillar One
On 30 January 2023 the OECD published the comments received on the design elements of Amount B under Pillar One relating to the simplification of transfer pricing rules. Comments were received from more than sixty businesses, institutes, NGOs and
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Malta implements DAC7 into domestic law
On 20 January 2023, Malta issued Legal Notice 8 of 2023 in the Official Gazette. Accordingly, Malta implemented regulations on the exchange of information on income from digital platforms (DAC7). This law is in accordance with the Council Directive
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Ireland: Revenue updates guidance on CbC reporting
On 25 January 2023, the Irish Revenue issued eBrief No. 018/23 on country-by-country (CbC) reporting - data access & usage. Accordingly, Tax and Duty Manual Part 38-03-20 has been updated. In addition to editorial changes, amendments of note
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Liberia signs MCAA for the exchange of CbCR
On 24 January 2023, the OECD has updated their list of signatories for the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country Reports (CbCR), showing that Liberia joined the agreement on 1 June 2022. According to
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Croatia joins multilateral agreement for exchange of information on income from digital platform
The OECD has announced that Croatia has signed the Multilateral Competent Authority Agreement on Automatic Exchange of Information regarding Income from Digital Platforms on 15 December 2022. The agreement provides for the automatic exchange of
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Luxembourg: Tax authority updates FAQs on CbC reporting
On 18 January 2023, the Luxembourg Tax Authority updated the frequently asked questions (FAQs) on country-by-country (CbC) reporting according to the guidance issued by the OECD in October 2022. The latest updates include the following
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South Africa: SARS issues new transfer pricing guidance for intra-group loans
On 17 January 2023, the South African Revenue Service (SARS) issued Interpretation Note 127 that explains how to calculate the taxable income of certain individuals or entities involved in international transactions, specifically in regard to loans
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Romania publishes draft bill on DAC7
13 January 2023, the Ministry of Finance (MoF) has released a draft ordinance to implement the provisions of the amending directive on administrative cooperation in the field of taxation (Council Directive (EU) 2021/514) (DAC7) in the fiscal
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