US: IRS publishes join statement with France on exchange of CbC reports for FY 2022-2023
On 7 December 2022, the Internal Revenue Service (IRS) published a joint statement with the competent authority of the United States of America and the competent authority of the French republic on the implementation of the spontaneous exchange of
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Papua New Guinea: National treasury presents budget 2023 raising the CIT rate for banks
On 29 November 2022, the Papua New Guinean Department of Treasury has announced the 2023 National Budget to Parliament, containing increased tax rate for banks. Accordingly, the corporate tax rate on banking institutions will rise to 45 percent from
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Spain: Council of Ministers adopts Royal-Decree implementing the reverse hybrid rules
On 18 October 2022, the Spanish Council of Ministers approved the Royal Decree-Law (RDL) implementing the reverse hybrid rules under the Anti-Tax Avoidance Directive 2017/952 (ATAD-2). The law generally aims to combat tax avoidance as a result of a
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Transfer Pricing Brief: December 2022
Argentina Compliance with BEPS standards: 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). See the story in
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South Africa: National treasury releases statement on BEPS MLI
On 1 December 2022, the South African National Treasury publishes a media statement on Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("Multilateral Instrument" or "BEPS MLI"). The Base
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Austria plans to expand the application on existing treaties under BEPS MLI
On 30 November 2022, the Austrian Council of Ministers approved the extension of the application on existing tax treaties under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting
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Germany publishes a draft bill updating list of participating jurisdictions under MCAA-CbC
On 23 November 2023, the German Ministry of Finance published a draft bill providing an updated list of jurisdictions participating under the Multilateral Competent Authority Agreement (MCAA) on the exchange of CbC reports. Accordingly, Germany will
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Mexico ratifies BEPS multilateral convention
On 22 November 2022, the Mexican President approved a Decree for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Mexico signed the MLI on 7 June 2017. Mexico
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OECD: Mutual Agreement Procedure Statistics for 2021
On 22 November 2022 the OECD published the mutual agreement procedure (MAP) statistics for 2021. The report covers 127 jurisdictions and is a part of the work on the minimum standard on BEPS action 14 (improving dispute resolution mechanisms). The
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Malta implements formal transfer pricing rules
On 18 November 2022, Malta published Legal Notice 284 of 2022 in the Official Gazette implementing transfer pricing rules into Malta’s tax code. These rules shall apply for basis years commencing on or after 1 January 2024 in relation to any
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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
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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
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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.
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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
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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
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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
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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
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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
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