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
See MoreBrazil and OECD present outline of new transfer pricing rules
On 12 April 2022 an event was held to present the outline of the new transfer pricing rules drafted by Brazil following a consultation process with the OECD. After Brazil had expressed the intention to become a full OECD member, Brazil and the
See MoreCyprus: Tax department publishes FAQs on DAC6 reporting
On 8 April 2022, the Tax Department of Cyprus has posted online Frequently Asked Questions (FAQs) regarding reportable cross-border tax arrangements (DAC6). The FAQs are currently available in Greek language and covered following
See MoreOECD: Strengthening Transfer Pricing Capacity in Mongolia
On 8 April 2022 the OECD published a tax and development case study entitled Tackling Multinational Tax Avoidance in Mongolia. In 2019 the OECD and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF)
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Ireland: Revenue issues an eBrief regarding DAC6
On 1 April 2022, the Revenue published an eBrief No. 078/22, which updates a manual regarding mandatory disclosure of reportable cross-border arrangements (DAC6). This was introduced by Finance Act 2021 and to provide additional guidance on the
See MoreUS: Treasury Department releases tax proposals from Budget 2023
On 28 March 2022, the Treasury Department of United States published details of tax proposals in the administration’s budget recommendations for FY 2023 in the “GreenBook.” The Greenbook describes following tax measures related to corporate
See MoreRussia raises the threshold for controlled transactions
On 22 March 2022, the Russian Parliament amended the criteria for controlled transactions for transfer pricing purposes. Accordingly, the general transaction threshold for transactions to be considered controlled transactions will be raised from
See MoreNigeria: FIRS posts digital FAQs regarding transfer pricing
On 15 March 2022, the Federal Inland Revenue Service (FIRS) made a post of frequently asked questions and answers (FAQs) related to transfer pricing (TP) through online. This includes applicable regulations and their scope; documentation
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