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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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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