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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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)
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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
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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
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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
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Czech Republic publishes FAQs on DAC7 reporting
The General Financial Directorate (GFD) has released a Frequently Asked Questions (FAQs) regarding the requirements of digital platform operators under the new reporting requirement for sellers and sales on their digital platforms. The first report
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South Korea approves budget for 2023
On 23 December 2022, South Korea’s National Assembly approved the budget for 2023 including the tax reform proposal for 2023. Accordingly, South Korea changes the existing tax-related measures including transfer pricing measures. The key tax
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Lithuania gazettes law for implementation of DAC7
Lithuania has published Law No. XIV-1658 in the Official Gazette to amend the Tax Administration Law related, this includes amendments for the implementation of new rules on the exchange of information on income from digital platforms (DAC7). This
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Belarus issues law on various tax amendment
On 4 January 2023, Belarus published Law No. 230-Z in the Official Gazette amending various tax measures. The following are the key amendments to the tax code: From 1 January 2023, the deadline for submitting transfer pricing documentation to
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Cyprus: Deadline extended for annual DAC7 reporting for 2023
On 17 January 2024, the Cyprus Tax Department declared the extension of the deadline for the annual DAC7 reporting for 2023 for all reporting platform operators. The new reporting deadline for 2023 is 16 February 2024. The new regulations take
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Israel publishes guidance on CbC reporting
The Israel Tax Authority (ITA) has released guidelines and Technical instructions for the filing of Country-by-Country (CbC) reports. Multi-National Enterprise (MNE) groups with a combined revenue of ILS 3.4 billion and above, starting from the 2022
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Belgium amends guidance on interest deduction rule
On 12 January 2023, Belgium issued Circular 2023/C/8, which provides instructions on the application of the 30% of EBITDA interest deduction limitation starting from 1 January 2019, in line with the EU Anti-Tax Avoidance Directive (ATAD). A summary
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US businesses not obligated to report digital asset transactions until regulations are established
On 16 January 2024, the US Treasury Department and IRS declared that businesses in the US are not required to report transactions involving digital assets the same way as they must report the receipt of cash until the Treasury and IRS issue
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Slovak Republic amends TP documentation requirements
The Slovak Ministry of Finance (MoF) has issued new guidelines to determine the content of transfer pricing (TP) documentation, effective for the tax period starting after 31 December 2022. The guidelines reflect an amendment to the income tax
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Argentina: AFIP introduces new mandatory disclosure regime for international transactions
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. It has replaced the previous mandatory reporting regime
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North Macedonia proposes amendments to TP reporting
Proposed amendments to the corporate income tax law regarding transfer pricing reporting would become effective from 1 January 2023. The proposed amendments include following changes: the requirement to submit a transfer pricing (TP) report to
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