Romania gazettes public CbC reporting directive
On 7 September 2022, the Romanian Official Gazette published the regulations to implement the EU Public country-by-country (CbC) Reporting Directive. The Directive requires qualifying multinational companies operating business in the EU to publicly
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Luxembourg: Finance Minister presents draft budget law 2023 to the Parliament
On 12 October 2020, Luxembourg’s Finance Minister presented the draft budget law 2023 to the Parliament. There are no measures regarding major tax reform or an increase in the tax rate in the draft budget law. The draft budget law sets out the
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Cyprus: Clarification Bilateral Agreement for exchange of CbC between Cyprus and the USA
On 13 October 2022, the Cyprus tax authority informed all legal entries and their representatives that the bilateral Competent Authority Arrangement (CAA) for the exchange of Country-by-Country (CbC Reports) between Cyprus and the United States of
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UK will increase corporation tax rate as planned
On 14 October 2022, the UK government announced that Corporation Tax will increase to 25% (currently 19%) from April 2023 as already legislated for, raising around £18 billion a year and acting as a down payment on its full Medium-Term Fiscal
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Mexico: Senate approves BEPS MLI
On 12 October 2022, the Mexican Senate approved 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 must now deposit its ratification
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Colombia: Congress approved Tax Reform Bill in the first debate
On 6 October 2022, the Colombian Congress approved Tax Reform Bill in the first debate. The Bill was presented to Congress on 8 August 2022. After the final approval of the Bill, the changes will become effective as of 1 January 2023. The main tax
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Belgium notifies TP penalties first time
The Belgian tax authorities have sent out the first penalty notifications for noncompliance to submit transfer pricing (TP) forms. Generally, TP documentation requirements is mandatory for Belgian entities exceeding the respective thresholds and
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Germany: CJEU has issued a decision on sanctions for non-compliance with TP documentation requirements
On 13 October 2022, the Court of Justice of the European Union (CJEU) ruled in case: C-431/21 on sanctions for non-compliance with transfer pricing (TP) documentation requirements. Under German law, there is a rebuttable presumption that the
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Mongolia signs MLI to implement tax treaty related BEPS measures
On 6 October 2022, Mongolia signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, at a signing ceremony held in Paris at the 14th meeting of the Inclusive Framework on BEPS. Mongolia
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Germany: Government publishes a draft bill for public CbC reporting
On 30 September 2022, the German Federal Ministry of Justice published draft legislation for the implementation of EU public country-by-country (CbC) reporting Directive 2021/2101 as regards the disclosure of income tax information by certain
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Transfer Pricing Brief: October 2022
Armenia Compliance with BEPS standards: On 14 September 2022, the Armenian Parliament (National Assembly) approved draft Bill No. K-294 for ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
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Puerto Rico extends tax returns and payment deadline due to Hurricane Fiona
On 27 September 2022, the Puerto Rico Treasury Department (PRTD) issued Administrative Determination No. 22-08 extending the due date for income tax returns and tax payments due to Hurricane Fiona. The PRTD extends the tax returns deadline until
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South Africa deposits ratification instrument for MLI
On 30 September 2022, South Africa deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI will come into effect for
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Belgium declares deadline for filing Local file forms
Belgian tax authority has declared the deadline for filing Local file forms (275LF) is 17 October 2022. The submission of a Local file is required for Belgian companies and permanent establishments (PEs) that meet at least one of three
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Ireland: Revenue updates guide to exchange of information under DAC6
On 26 September 2022, the Irish Revenue published an eBrief No. 175/22 on Guide to Exchange of Information. Accordingly. Tax and Duty Manual Part 35-01-01a (the Guide) under Council Directive 2011/16/EU, Ireland’s double taxation agreements and
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Greece amends corresponding adjustment provisions for Transfer Pricing
On 23 September 2022, Greece published Law No. 4972/2022 in the Official Gazette containing various tax measures including transfer pricing. The law amends an existing provision on transfer pricing adjustments upwards to provide for corresponding
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Armenia: Parliament approves a bill to ratify BEPS MLI
On 14 September 2022, the Armenian Parliament (National Assembly) approved draft Bill No. K-294 for ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). On 7 June 2017, Armenia signed the agreement
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Hong Kong: BEPS MLI enters into force
On 16 September 2022, OECD has published the update list of signatories and parties to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, MLI entered into force for
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