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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
France: Tax Authority issues new DAC7 guidelines
On 11 January 2023, the French Tax Authority has issued guidance, known as BOI-INT-AEA-30, regarding the obligations imposed on platform operators under the new rules of the Digital Platforms Directive (DAC7). DAC7, based on Council Directive (EU)
See More
US: IRS invites to comments on CbC report form
As part of its continuing effort to reduce paperwork and respondent burden, on 5 January 2023, the Internal Revenue Service invited the general public and other federal agencies to take this opportunity to comment on proposed and/or continuing
See More
Poland: MoF publishes base interest rates for transfer pricing purpose
On 23 December 2022, the Polish Ministry of Finance published a notice in the official gazette, establishing base interest rates and margin rates for the purposes of transfer pricing for individual and corporate income taxes. The notice specifies
See More
Iceland: Tax administration announces deadline for 2022 CbC notification
On 2 January 2023, the Icelandic Directorate of Internal Revenue published Notice 1609/2022, announcing the Jan. 31 deadline for submitting country-by-country (CbC) reporting for the fiscal year 2022. The notice contains that the notification must
See More