Australia updates local file and master file guidelines for 2022
On 9 August 2022, the Australian Taxation Office (ATO) updated guidance on the Local and Master file for 2022 along with instructions. The guidance applies to reporting periods beginning on or after 1 January 2021. The local file must be
See MoreBulgaria Ratifies MLI Convention
On 17 June 2022, Bulgaria ratified the OECD Multilateral Convention (MLI) (2017) and published it in the Official Gazette (No. Decree No. 153). Bulgaria also submitted its provisional MLI position at the time of signature, listing its
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Singapore: IRAS Publishes Updated E-Tax Guide on GST TP Adjustments
On 3 August 2022, the Inland Revenue Authority of Singapore (IRAS) updated the GST-E Tax Guide on Transfer Pricing Adjustments (Third Edition). The e-Tax guide explains the GST treatment for adjustments on the transfer prices of transactions between
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Russia updates the list of foreign states for automatic exchange of CbC reports
Recently, the Federal Tax Service of Russia published (Order No. ED-7-17/449) a new list of foreign states (territories), with which Russia will automatically exchange Country-by-Country (CbC) reports. Accordingly, the following states are
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French Court of Appeal of Paris clarifies TP rules for cross-border group companies
Recently, the French Court of Appeal of Paris issued a decision in the case of France v. Ferragamo France (No. 20PA0360), in June 2022, explaining the transfer pricing (TP) rules for cross-border group companies. The taxpayer (Ferragamo France),
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Hungary gazettes the 2023 Budget bill including transfer pricing changes
On 27 July 2022, the Hungarian Official Gazette published the Budget Bill (Law XXIV of 2022) providing for amendments to the Hungarian transfer pricing regulations. The law was passed by the parliament on 19 July 2022. The law includes the following
See MoreUkraine: STS explains international taxation during martial law
On 3 August 2022, the State Tax Service (STS) of Ukraine explained the rights and obligations of taxpayers and supervisory authorities in matters of international taxation during martial law, taking into account the Ukraine- Russia war. Statute
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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
See MoreHungary: 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
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