Netherlands: Amount B will not be introduced for Dutch taxpayers
The Netherlands government has announced, on 4 December 2024, in a decree that it will not be adopting the OECD’s new transfer pricing rules (Amount B). However, it will acknowledge other countries' adoption of the OECD's new transfer pricing
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Germany: Fourth Bureaucracy Relief Act updates transfer pricing documentation requirements
The Fourth Bureaucracy Relief Act, which goes into effect on 1 January 2025, brings major updates to transfer pricing documentation requirements in Germany. This latest amendment brings the following changes: Transfer pricing documentation
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Poland consults updated low-tax jurisdictions list, removes Andorra
Poland’s Ministry of Finance has initiated a public consultation on a proposed legislation that identifies countries and territories involved in harmful tax practices, classifying them as low-tax jurisdictions. The bill proposes to remove
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Brazil consults commodity transfer pricing
Brazil's revenue authority has launched a public consultation on a proposed amendment to its transfer pricing rules on 27 November 2024. The proposed amendment concerns Normative Instruction RFB No. 2,161 of September 28, 2023, addressing
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Ireland approves new global tax reform rules
Ireland's parliament has passed a bill simplifying transfer pricing for marketing and distribution and amending global minimum tax rules on 6 November 2024. This legislation was enacted as part of the Finance Bill 2024, which was approved by both
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Chile updates tax compliance law, introduces changes to GAAR, transfer pricing, and CFC
Chile's Internal Revenue Service (SII) has announced that the Law on Compliance with Tax Obligations (Law No. 21.713) has been published in the Official Gazette on 24 October 2024. General and Special Anti-Avoidance Rules changes The General
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Germany passes Fourth Bureaucracy Relief Act, cuts accounting document retention and updates transfer pricing rules
Germany’s Federal Council (Bundesrat) passed the Fourth Bureaucracy Relief Act on 18 October 2024 following its approval by the Bundestag (lower house of parliament) on 26 September 2024. One key aspect of the Act is that it reduces
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Ukraine clarifies corporate tax rules for German entities under transfer pricing provisions
The Ministry of Finance of Ukraine has issued a clarification concerning the corporate taxes of the Federal Republic of Germany and their relevance to Ukrainian tax law, particularly in the context of transfer pricing regulations on 30 September
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Denmark: 2024-25 legislative plan proposes updates to minimum tax, transfer pricing to match OECD rules
Denmark's government announced the legislative programme for the parliamentary year 2024-25 on 1 October 2024. The bill follows up on the government platform "Responsibility for Denmark" from December 2022 and the agreement on "A Stronger Business
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Peru enacts new rules for determining FMV of non-listed securities in related-party transactions
The Peruvian Government enacted Legislative Decree 1663 on 24 September 2024, amending the Income Tax Law to introduce rules for determining the fair market value (FMV) of non-listed securities in related-party transactions. This closes a gap in the
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Chile passes tax compliance bill with income, VAT, transfer pricing measures
Chile’s Senate has approved the Tax Compliance Bill on 24 September 2024, which will be presented to the Lower House for final approval. The newly approved tax measures include modifications to the general anti-avoidance rule (GAAR), statute of
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Peru clarifies informative affidavit requirements for transfer pricing compliance
The National Superintendency of Customs and Tax Administration (Sunat) released Report No. 000063-2024-SUNAT/7T0000 on 9 September 2024, clarifying issues related to the informative affidavit required for import and export transactions involving
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Russia: FTS issues new transfer pricing reporting requirements
Russia's Federal Tax Service (FTS) has introduced new guidelines requiring detailed disclosure of the price formation chain in controlled transactions for transfer pricing purposes. According to Guidance Letter ZG-2-13/11134, issued on 2 August
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New Zealand issues Commissioner’s Statement on withholding in transfer pricing
The New Zealand tax authority released the Commissioner's statement (CS) 24/02: Withholding obligations arising in relation to transfer pricing arrangements on 30 August 2024. CS 24/02 details the Commissioner's stance and operational strategy
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UAE: FTA clarifies related parties definition for government entities
The UAE’s Federal Tax Authority (FTA) published a public clarification CTP002 of 21 July 2024, which clarified the definition of "related parties" where there is common ownership and/or control through a government entity. The corporate tax in
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Ecuador updates transfer pricing report guideline, introduces new penalties
The Internal revenue service (SRI) has issued “Resolution No. NAC-DGERCGC24-00000020” in the Ecuadorian Official Gazette on 28 May, 2024, which outlines details of the transfer pricing annex concerning related party transactions and the
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Slovak Republic releases 2023 transfer pricing documentation guidelines
Slovak Republic's Ministry of Finance has issued guidelines (MF/020061/2022-724) outlining the requirements for transfer pricing documentation for 2023. These guidelines categorise transfer pricing documentation into three types: Full-scope
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Hungary releases 2024 audit plan with targets transfer pricing
Hungary's National Tax and Customs Administration (NAV) has released its audit strategy for the 2024 calendar year, highlighting transfer pricing as its key area of focus among other sectors. The new transfer pricing reporting obligation introduced
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