Luxembourg: Government submits draft bill on transfer pricing and general tax procedures
On 28 March 2023, the Luxembourg government submitted Bill No. 8186 to the Parliament. The bill includes changes in advance pricing arrangement (APA), mutual agreement procedure (MAP), compliance with transfer pricing documentation requirements, and
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South Africa issues interpretation note on definition of associated enterprise
On 17 April 2023, the South African Revenue Service (SARS) published an interpretation note 128 on the definition of “associated enterprise”. This note provides guidance on the interpretation and application of the definition of “associated
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Malta: CFR updates FAQs on DAC6
On 13 April 2023, the Maltese Commissioner for Revenue (CFR) updated “frequently asked questions” (FAQs) on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements (DAC6). Accordingly, the following questions
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Saudi Arabia: ZATCA approves amendment to the TP Bylaws
On 20 March 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) approved Decision No. 8-2-23 to amend the Transfer Pricing (TP) Bylaws. The approved amendments to the TP Bylaws in Saudi Arabia will expand the scope of the provisions to
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Brazil: Lower House passes transfer pricing reform measure
On 30 March 2023, the Brazilian Lower House of Congress adopted Measure No. 1,152 to overhaul its transfer pricing system that was introduced on 29 December 2022. In addition to introducing the arm's length principle into the Brazilian transfer
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Malta: CFR provides guidelines on DAC6 notification obligations for intermediaries
On 8 March 2023, the Maltese Commissioner for Revenue (CFR) provides guidelines in relation to the waiver from filing information in respect of a reportable cross-border arrangement (DAC6). Following the CJEU decision on 8 December 2022, Maltese
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Brazil issues normative instruction establishing new transfer pricing regulations for 2023
On 24 February 2023, the Brazilian Federal Revenue Office published the Normative Instruction No. 2.132 which establishes the regulation of the taxpayer's choice to apply the new transfer pricing rules according to Provisional Measure (PM) No.
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Malta: CFR extends DAC6 annual notification deadline for non-disclosing intermediaries
On 17 February 2023, the Maltese Commissioner for Revenue (CFR) notified that the deadline for annual notification of cross-border arrangements (DAC6) by non-disclosing intermediaries is being extended. Accordingly, non-disclosing intermediaries
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Finland: Tax agency issues guidance on application of OECD guidelines for domestic TP rules
On 8 February 2023, the Finnish tax administration issued guidance No.VH/5942/00.01.00/2022 on the application of OECD transfer pricing guidelines to domestic transfer pricing rules. The purpose of the guidance is also to summarize the effects of
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Argentina: AFIP introduces new mandatory disclosure regime for international transactions
On 27 December 2022, Argentina's federal tax authority (AFIP) released General Resolution No.5306/2022, establishing a new mandatory disclosure regime for certain international transactions. It has replaced the previous mandatory reporting regime
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Brazil issues new transfer pricing legislation to align with OECD transfer pricing guidelines
On 29 December 2022, the outgoing Brazilian President issued draft legislation MP 1.152 to align Brazil’s unique transfer pricing system with the OECD Transfer Pricing Guidelines. The news rule will be compulsory for 2024, for fiscal year 2023,
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Ireland: President signs the Finance Bill 2022 into Law
On 15 December 2022, Michael D. Higgins, the President of Ireland signed the Finance Bill 2022 into Law. The Finance Act contains new tax measures including changes in corporate income tax and transfer pricing related measures. The main tax measures
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Malta implements formal transfer pricing rules
On 18 November 2022, Malta published Legal Notice 284 of 2022 in the Official Gazette implementing transfer pricing rules into Malta’s tax code. These rules shall apply for basis years commencing on or after 1 January 2024 in relation to any
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United Kingdom adopts OECD TP Guidelines 2022
On 9 November 2022, the UK Official Gazette published Statutory Instrument No. 2022/1147, on transfer pricing (TP) guidelines. The statutory instrument outlines the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax
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Ireland: Government publishes Finance Bill 2022
On 20 Oct 2022, Ireland’s Minister for Finance Paschal Donohoe published the Finance Bill 2022 as part of the Irish budget. The Finance Bill contains new tax measures that were not included in the budget presented in September 2022. The main tax
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South Africa introduces draft interpretation on definition of “associated enterprises”
On 14 October 2022, the South African Revenue Service (SARS) published a draft interpretation note on the definition of "associated enterprise" for public comment. This draft note provides guidance on the interpretation and application of the
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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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Poland releases ordinance on transfer pricing information
On 13 September 2022, the Polish Official Gazette released Ordinance Nos. 1923 and 1934, clarifying transfer pricing information in the scope of personal and corporate income tax. The ordinances include the following tax measures: Defining the
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