Ireland: Revenue issues guidance on attribution of profits to a branch
On 7 September 2022, the Irish Revenue published an eBrief No. 166/22 on the attribution of profits to a branch. Accordingly, Tax and Duty Manual Part 02-02-04a has been issued to provide an overview and guidance in relation to the attribution of
See MoreSlovak Republic approves draft bill to amend transfer pricing rules
The government of the Slovak Republic has approved the draft law amending the Income Tax Act and the Act on Tax Administration. The amendments include following changes: implementation of rules on restriction of interest deduction in accordance
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Paraguay updates list of low-tax Jurisdictions
On 24 August 2022, the Paraguayan tax authority (SET) issued General Resolution No. 118/2022, concerning the Transfer Pricing Technical Study (ETPT) and a list of low-tax jurisdictions. The amended list of low-tax jurisdictions are
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Lithuania approves draft bill relating to the VAT registration threshold for related persons
On 12 August 2022, the Lithuanian Parliament accepted for consideration Bill (No. XIVP-1915), relating to the VAT Law on Calculating the VAT Registration Threshold for Related Persons. Accordingly, when related persons carry out economic
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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
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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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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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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
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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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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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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: New Transfer Pricing Country Profiles Published
On 9 June 2022 the OECD released new transfer pricing country profiles for Egypt, Liberia, Saudi Arabia and Sri Lanka. The OECD transfer pricing profiles cover the OECD member countries and a number of member countries of the Inclusive
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Netherlands publishes latest DAC6 reporting guidelines
The Netherlands Tax and Customs Administration have published latest user guidelines for the use of the Mandatory Disclosure/DAC6 data portal for reporting potentially aggressive cross-border tax arrangements. As a result of the Dutch
See MoreLuxembourg: Tax Authorities updates guidance on DAC6
On 4 May 2022, the Luxembourg Tax Authorities has updated guidelines concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) as per Council Directive (EU) 2018/822 of 25 May 2018. The guidance mainly covers
See MoreRussia clarifies the criteria for transfer pricing controlled transactions
On 26 April 2022, the Ministry of Finance and Federal Tax Service (FTS) published a Guidance Letter 03-12-12/1/37761 clarifying the criteria for qualifying transactions as controlled for transfer pricing purposes. The letter states that taxpayers
See MoreMalta: CFR publishes FAQs on DAC6
On 29 April 2022, Malta’s Commissioner for Revenue (CFR) has published “frequently asked questions” (FAQs) on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements (DAC6). The FAQs contains the definition of
See MoreKenya: Transfer pricing measures in Finance Bill 2022
On 12 April 2022, the Finance Bill 2022 was presented in the National Assembly of Kenya, which provides following tax measures related to transfer pricing. The Bill aims to amend Section 18(A) of the ITA to include transactions between residents
See MoreBrazil: Government proposes new transfer pricing system
On 12 April 2022, the tax authority and Organisation for Economic Co-operation and Development (OECD) met to discuss Brazil’s proposal for a new transfer pricing (TP) system. The Brazilian Economy Minister, Paulo Guedes, said that the creation
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