Azerbaijan plans to increase CbC reporting penalty
On 16 November 2022, Azerbaijan submitted a proposal to the Parliament to increase the penalty for failure to submit country-by-country (CbC) reports. Accordingly, penalties for failure to file CbC reports or to comply with other CbC-related
See More
Australia: ATO releases updated interest rate for simplified transfer pricing record keeping options for loans
On 17 November 2022, the Australian Taxation Office (ATO) published an updated version of Practical Compliance Guideline (PCG) 2017/2 related to the eligibility criteria for applying simplified transfer pricing record keeping options for low level
See More
Belgium: Parliament approves amendments on statute of limitations
On 10 November 2022, the Belgian parliament approved the law amending the statutes of limitations periods. The statute of limitations periods is set as follows: A standard 3-year statute of limitations where a return has been timely filed.
See More
Argentina: Commission on foreign affairs endorses a bill to ratify MLI
On 8 November 2022, the Argentine Commission on Foreign Affairs accepted a bill to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). On 7 June 2017, Argentina signed the MLI containing a
See More
Costa Rica extends the deadline for filing informative returns for dormant companies
On 9 November 2022, Costa Rica published the Resolution No.DGT-R-033-2022 regarding further extension of deadline for filing informative returns for dormant companies. This is the third extension of the filing deadline. Previously, it was extended
See More
United Kingdom adopts OECD TP Guidelines 2022
On 9 November 2022, the UK Official Gazette published Statutory Instrument No. 2022/1147, on transfer pricing (TP) guidelines. The statutory instrument outlines the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax
See More
Germany: Federal Cabinet approves CbC reports exchange agreement with US
On 4 November 2022, the German Upper House of Parliament (Bundesrat) approves bill No. 567/22 for consideration to ratify the competent authority agreement (CAA) on the exchange of country-by-country (CbC) reports with the US. The competent
See More
Poland: President signs the Polish Deal 3.0 including transfer pricing changes
On 21 October 2022, the President of Poland signed the Law of 7 October 2022 amending the Corporate Income Tax Act (referred to as Polish Deal 3.0), including certain transfer pricing changes. One of the most significant changes to transfer pricing
See More
Indonesia: DGT publishes list of CbC reporting jurisdictions
On 2 November 2022, the Indonesian General Directorate of Taxes (DGT) published a list of jurisdictions participating in the automatic exchange of Country-by-Country (CbC) reports and with which a qualifying competence authority agreement (QCAA) is
See More
Denmark issues guidance on DAC7 reporting requirements
On 2 November 2022, the Danish Customs and Tax Administration published guidance on DAC7 registration and reporting requirements for digital platform operators under Council Directive (EU) 2021/514. This directive has been published on 25 March
See MoreUkraine joins MCAA on the exchange of CbCR
On 4 November 2022, the Ukrainian State Tax Service (STS) announced that Ukraine joined the Multilateral Competent Authority Agreement (MCAA) on the exchange of country-by-country reports (CbCR) on 3 November 2022. Ukraine joins the MCAA-CbC to
See More
Georgia joins MCAA on automatic exchange of financial account information
On 9 September 2022, Georgia has joined the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (MCAA). The agreement provides for all forms of administrative assistance in tax matters: exchange of
See More
Transfer Pricing Brief: November 2022
Azerbaijan Information exchange-Bilateral: On 26 October 2022, the President of the Republic of Azerbaijan published a law ratifying the Inclusive Framework on Base Erosion and Profit Shifting (BEPS), which was approved by the President on 11
See More
Singapore: IRAS updates e-tax guide on country-by-country reporting
On 31 October 2022, the Inland Revenue Authority of Singapore (IRAS) published the fourth edition of its e-Tax Guide concerning country-by-country (CbC) reporting. The updated guide includes the following main amendments: Amended to incorporate
See MoreKenya signs multilateral competent authority agreement on exchange of CbC reports
On 9 September 2022, Kenya signed the multilateral competent authority agreement on the exchange of Country-by-Country Reports (CbC MCAA). The CbC MCAA was developed jointly by the OECD and the Council of Europe in 1988 and amended by Protocol in
See More
Hungary submits a draft legislation to Parliament on APA and CbCR
On 18 October 2022, Hungarian Ministry of Finance has submitted a draft legislation to the Parliament proposing the amendments of advance pricing arrangements (APAs) and introduction of public CbC reporting. Effective from 1 January 2023, the
See MoreEstonia: Government approves Law on DAC7
On 20 October 2022, the Estonian Government approved Law regarding new reporting obligations Council Directive (EU) 2021/514 for digital platform operators (DAC7) into domestic law. This directive has been published on 25 March 2021, entered into
See More
Greece: Parliament adopts a draft bill to update code of tax procedure
On 27 October 2022, the parliament of Greece adopted a tax law ratification bill for consideration. The bill includes the following measures: Includes definitions; Establishment of regulatory procedures for tax declaration and payment;
See More