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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Singapore: IRAS updates TP Guidelines on indicative margin for related-party loans
On 3 January 2023, the Inland Revenue Authority of Singapore (IRAS) published updated transfer pricing (TP) guidelines on indicative margin for related-party loans. IRAS publishes the indicative margin at the beginning of each calendar year. The
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Transfer Pricing Brief: January 2023
Austria Compliance with BEPS standards: 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
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Colombia issues decree on the tax return and TP documentation deadline in 2023
On 16 December 2022, the Colombian Ministry of Finance Published Decree 2487 specifying the deadlines for filing and payment of the tax return (declaration) in 2023 and the deadline for transfer pricing (TP) documentation. Some of the key deadlines
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Indonesia publishes regulation providing authorization to implement BEPS pillar two
On 20 December 2022, Indonesia published Government Regulations No. 55 of 2022 with provisions to implement the OECD's two-pillar solution to address the tax challenges arising from the digitization of the economy. This includes authorizing the
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South Africa: BEPS MLI enters into force
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for South Africa on 1 January 2023. With regard to the double taxation agreements between South Africa and
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Germany passed law for implementation of DAC7
On 16 December 2022, Germany passed the DAC7 to modernize tax procedural law. The new law amended Section 90 of the General Tax Code (GTC) and tightened the rules on transfer pricing documentation by allowing tax authorities to request transfer
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Panama declares CbC Reporting deadline
On 30 December 2022, the Resolution 201-9507 was published in Official Gazette No. 29692-A, that extended the deadline for submitting the country-by-country (CbC) report for fiscal year 2021 to 15 January 2023. The CbC report must be submitted
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Brazil issues new transfer pricing legislation to align with OECD transfer pricing guidelines
On 29 December 2022, the outgoing Brazilian President issued draft legislation MP 1.152 to align Brazil’s unique transfer pricing system with the OECD Transfer Pricing Guidelines. The news rule will be compulsory for 2024, for fiscal year 2023,
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Belgium enacts DAC7
On 30 December 2022, Belgium enacted a law for implementing into domestic legislation, the EU Directive imposing reporting and exchange of information requirements concerning the activities of certain digital platform operators situated both inside
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Costa Rica: Ministry of Finance issues decree setting the corporate tax brackets for 2023
On 23 December 2022, the Costa Rican Ministry of Finance published Executive Decree No.43852-H updating the individual and corporate income tax thresholds for 2023. Accordingly, companies whose gross income does not exceed the amount of
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Ireland: President signs the Finance Bill 2022 into Law
On 15 December 2022, Michael D. Higgins, the President of Ireland signed the Finance Bill 2022 into Law. The Finance Act contains new tax measures including changes in corporate income tax and transfer pricing related measures. The main tax measures
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Spain releases legislation to implement EU public CbC reporting directive
On 22 December 2022, the Spanish government published the legislation implementing the European Union (EU) Directive (2021/2201) on Public Country-by-Country (CbC) Reporting (CbCR). According to the EU Public CbCR Directive, both EU-based
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Bulgaria gazettes text of MCAA for digital platforms income
On 16 December 2022, the Bulgarian official gazette published the text of the multilateral competent authority agreement on automatic exchange of information on income derived through digital platforms (DPI-MCAA). It was signed on 9 November
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Azerbaijan joins the inclusive framework on BEPS
On 16 December 2022, the Organization for Economic Cooperation and Development (OECD) announced that Azerbaijan joined the inclusive framework on Base Erosion and Profit Shifting (BEPS). Collaborating on an equal footing with all other members of
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Serbia: Ministry of Finance release arm’s length interest rates for 2022
On 16 December 2022, the Serbian Ministry of Finance published the Rulebook on arm’s Length interest rates applicable for 2022 that applies to related parties’ loans. The rulebook comes into force on 24 December 2022. Taxpayers can use the
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Morocco suspends CbC reporting requirement temporarily
On 16 December 2022, the Moroccan tax authority published an announcement, which temporarily suspending the requirement to file a country-by-country (CbC) report for companies that are part of multinational enterprises (MNEs) operating in Morocco
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