Ireland provides guidance on the tax deductibility of DSTs
On 5 August 2022, the Irish Revenue published an eBrief No. 158/22 on Tax and Duty Manual Part 04-06-03 that provides guidance on the tax deductibility of Digital Services Taxes (DSTs). The purpose of this manual is to outline the rules in relation
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Transfer Pricing Brief: August 2022
Cyprus Scope of transfer pricing rules: 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
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Hungary: Parliament adopts a bill imposing additional requirement for TPD
On 19 July 2022, the Hungarian Parliament passed a bill introducing important changes to the transfer pricing rules. The law introduces a significant additional reporting requirement for intra-group transactions and requires transfer pricing
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UK plans to introduce three-tiered documentation requirements
On 20 July 2022, the UK Government published draft legislation as part of the Finance Bill 2022-23 which will make it a requirement for large multinational businesses operating in the UK to keep and retain transfer pricing (TP) documentation in a
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Dominican Republic publishes resolution on inflation adjustments
On 20 July 2022, the Dominican Republic tax authorities published a Resolution (DDG-AR1-2022-00006) on multipliers and adjustments for the fiscal year closing in June 2022. The Resolution includes the following changes: Set the inflation
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Israel introduces three-tiered TP documentation requirements
On 30 June 2022, the Israeli Parliament passed legislation to amend Section 85A of the Income Tax Ordinance (ITO) and its regulations, by introducing three-tiered transfer pricing documentation requirements of BEPS Action 13. The legislation
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Philippines issues MAP Guidelines
The Philippines Bureau of Internal Revenue (BIR) has published Revenue Regulations No. 10/2022 on mutual agreement procedure (MAP) guidelines and process for requesting MAP assistance. The MAP article in the Double Taxation Agreements or tax
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Thailand: BEPS MLI in Force
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Thailand on 1 July 2022. With regard to the double taxation agreements between Thailand and other
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Netherlands publishes new transfer pricing decree
On 1 July 2022, the Netherlands Ministry of Finance issued Decree No. 2022-0000139020 related to the application of the arm's length principle and the OECD transfer pricing guidelines. The New Decree replaces the previous transfer pricing (TP)
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Nigeria: FIRS extends tax return filing due date for companies
On 4 July 2022, the Federal Inland Revenue Service (FIRS) of Nigeria has announced to extend the submission of company income tax return for the 2022 year of assessment. Accordingly, the filing of Companies Income Tax Returns for the 2022 Year of
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Kenya: Major changes in transfer pricing rules under Finance Act 2022
On 8 July 2022, the Kenyan Finance Act 2022 was gazetted which was signed into law by the President on 21 June 2022. The law introduced a number of changes to the transfer pricing regulatory framework in Kenya that will have far-reaching
See MoreParaguay extends deadlines of TP returns
On 23 June 2022, the tax authority has extended the deadlines to submit the transfer pricing (TP) informative returns related to commodities exports through General Resolution 116. The Resolution came into force on 24 June 2022. The deadlines are
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Saudi Arabia issues draft Transfer Pricing Bylaws for public consultation
On 4 July 2022, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued a draft of Transfer Pricing (TP) Bylaws and invited public consultation. The public consultation period is open until 30 July 2022. The final Transfer Pricing Bylaws
See MoreGreece publishes lists of Jurisdictions for Automatic Exchange of Information on CbC reporting
Recently, the Ministry of Finance published a decision containing the list of jurisdictions to which it will apply the OECD Agreement on the Automatic Exchange of Information on Country-by-Country Reporting (CbC) (2016) in 2022 concerning the
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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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