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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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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