India: CBDT notifies the arm’s-length pricing variation limit for 2022-23
On 28 June 2022, the Indian Central Board of Direct Taxes (CBDT) issued Notification No. 70/2022, clarifying the calculation procedure of the arm’s length price under the income tax act. The notification provides a tolerance range of 1 % for
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Portugal extends the deadline to submit the TP file
On 6 July 2022, the government announced that it would extend the transfer pricing (TP) deadlines for preparation and/or submission to the tax authority. The deadline is extended from 15 July to 15 September 2022 without any accruals or
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Cyprus: Parliament adopts new transfer pricing legislation
On 30 June 2022, the Cyprus House of Representatives enacted detailed transfer pricing legislation amending the Cyprus Income Tax Law (ITL) and the issuance of Regulations. The amendment includes the new TP documentation requirements and a framework
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Lithuania amends the APA rules
Recently, the State Tax Inspectorate of the Ministry of Finance of the Republic of Lithuania revised the Lithuanian Advance Pricing Agreements (APAs), which came into effect on 31 March 2022. Among other changes, the amendments also provide for
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OECD: Model Manual on Exchange of Information Now Available in Four Languages
On 7 July 2022 the OECD noted on its website that the Model Manual on Exchange of Information is now available in four languages – English, French, Spanish and Portuguese. The current version of the Manual was issued on 16 September 2021 in the
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Germany: MoF publishes a draft decree-law regarding the transfer of functions
On 5 July 2022, the German Federal Ministry of Finance published a draft decree-law regarding the transfer of functions. The aim of the draft decree-law is to adapt and restructure the existing regulations on the arm's length principle with the
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South Korea: NTS updates MAP guidance
On 30 June 2022, South Korea’s National Tax Service (NTS) has issued updated Mutual Agreement Procedure (MAP) guidance on the official website. The guidance prescribes the following key areas: Overview of MAP; Application of MAP;
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Transfer Pricing Brief: July 2022
Dominican Republic CbC reporting requirement-Threshold: On 22 June 2022, the Directorate General of Internal Revenue (DGII) published a Notice (No. 18-22) clarifying CbC for Multinational Enterprises (MNEs). If the group reports and is
See MoreTanzania: National Assembly approves Finance Bill 2022
On 28 June 2022, the National Assembly approved Finance Bill 2022 which contains the measures of the Budget for 2022/23. The Finance Act 2022 was published on 30 June 2022 in the Tanzanian Official Gazette. This Act shall come into operation on 1
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Ireland: Revenue issues eBrief on anti-hybrid rules guidance
On 29 June 2022, the Irish Revenue published an eBrief No. 137/22 to announce a manual to update the guidance on anti-hybrid rules. Accordingly, Tax and Duty Manual Part 35C-00-01 - Guidance on the Anti-hybrid rules - has been updated for
See MoreGreece enacts ATAD’s reverse hybrid rule
On 30 June 2022, the government of Greece enacted legislation implementing ATAD's reverse hybrid rule with retroactive effect from 1 January 2022. The rule does not apply to collective investment vehicles. The new rule applies to situations where
See MoreSpain confirms the completion of its internal procedures for the entry into force of the MLI
On 28 June 2022 OECD published the update status of signatory countries regarding BEPS MLI. Accordingly, on 1 June 2022, Spain submitted its notification confirming the completion of its internal procedures for the entry into force of the
See MoreKenya: President gives assent to the finance act 2022
On 21 June 2022, Kenya’s President has given his assent to the Finance Act 2022 which was presented to the Parliament on 13 April 2022. The act contains following tax measures mostly take effect on 1 July 2022. The Bill proposed to introduce
See MorePoland: MoF extends the filing deadline for corporate income tax return
On 22 June 2022, the Polish Ministry of Finance has published a draft decree extending the deadline for submitting the CIT-8E return. Accordingly, the deadline for submitting the CIT-8E return is 30 September 2022. The extension applies to all
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Hungary: Finance minister presents 2023 budget bill to parliament
On 22 June 2022, the Hungarian finance minister submitted the 2023 Budget Bill in parliament providing following tax measures related to transfer pricing changes. The bill proposes to revise the regulation of the application of the interquartile
See MoreDominican Republic: DGII publishes clarifications on CbC Reporting for MNE
On 22 June 2022, the Directorate General of Internal Revenue (DGII) published a Notice (No. 18-22) clarifying Country-by-Country Reporting (CbC) for Multinational Enterprises (MNEs). The notice includes the following procedures: Submit CbC
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Austria: MOF Updates Guidance on COVID-19 treaty Issues
On 20 June 2022, the Ministry of Finance published a Circular (no. 2022-0.433.029 of 17 June 2022) clarifying various tax treaty issues that have arisen due to the COVID-19 pandemic, including permanent establishments(PE) and the application of the
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OECD: Tax Administration 2022
On 23 June 2022 the OECD’s Forum on Tax Administration (FTA) issued Tax Administration 2022, which is the tenth edition of the report. The report sets out internationally comparative data on various features of tax systems and tax
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