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
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 administrationâs budget recommendations for FY 2023 in the âGreenBook.â The Greenbook describes following tax measures related to corporate
See MoreKazakhstan: Government invites public comments regarding transfer pricing amendments
On 16 March 2022, the State Revenue Committee announced that they opened a public consultation on a draft bill to amend transfer pricing rules. The deadline for this public comments is 8 April 2022. The draft Bill contained the following measures
See MoreGreece: AADE issues a Circular to provide guidance on CFC rules
On 23 February 2022, the Greek Public Revenue Authority (AADE) published Circular E. 2018 of 23 February 2022, providing guidance on the application of Controlled Foreign Companies (CFC rules). This is introduced as from 1 January 2019 in line with
See MoreMalta seeks comments on draft Transfer Pricing Rules
On 22 December 2021, Maltaâs Commissioner for Revenue (CFR) has published draft Transfer Pricing Rules on its website for public consultation. The consultation period will end on 28 February 2022, and the draft Transfer Pricing Rules shall come
See MoreAzerbaijan modifies the Tax Code for TP, CbC Reporting, and CFC rules
On 16 November 2021, Azerbaijan has modified its Tax Code including three main changes regarding Transfer Pricing (TP), country by country (CbC) reports, and controlled foreign company (CFC) rules. The changes will be implemented from 1 January
See MoreUkraine: STS clarifies the controlled transactions criteria for TP purposes
Recently, the State Tax Service (STS) has clarified the criteria for classifying transactions between related parties (Ukrainian residents and non-residents) as controlled for transfer pricing (TP) purposes. Under Ukrainian transfer pricing
See MoreUkraine issues taxation of income of non-residents
On 27 Aug 2021, the Ukrainian Ministry of Finance has issued Order No. 480 regarding the taxation of income of non-residents, which are equated to dividends. The Order provides clarification on the application of the new rules of taxation of income
See MoreKenya enacts Finance Act 2021
On 1 July 2021, Kenya published the Finance Act 2021 in the official gazette. The act was signed into law by the president on 29 June 2021. The act was presented to Parliament by the Kenyan Treasury Cabinet Secretary on 4 May 2021. The act
See MoreJordan introduces transfer pricing rules for MNE groups
On 7 June 2021, the Hashemite Kingdom of Jordan has published Regulation No. 40 of 2021 in the Official Gazette. The Regulation has introduced transfer pricing rules for multinational entity (MNE) groups with effect from 7 July 2021. The Regulation
See MoreKenya publishes Finance Bill 2021
On 5 May 2021, the Parliament of Kenya has published the finance bill 2021 providing the following tax measures: Reintroduce the definition of the term ââControlâ The definition of the term âcontrolâ was deleted with the
See MoreCroatia: Government fixes related party interest rate for 2021
The Croatian Government has changed the armâs length interest rate from 3.42% per annum to 3% per annum regarding loans between related parties for the year 2021. This rate is effective from 1st January 2021 and applies for loans between resident
See MoreSouth Africa: Government Officially publishes 2020 Tax Amendment Acts
On 20 January 2021, the Treasury Department Officially published the 2020 Tax Amendment Acts. The following Amendment Acts were promulgated: Rates and Monetary Amounts and Amendment of Revenue Laws Act 22 of 2020.Taxation Laws Amendment Act 23
See MoreSingapore issues advance ruling summary on determination of related parties
On 4 January 2021, the tax Authority of Singapore has published Advance Ruling Summary No. 1/2021, regarding the determination of related parties for transfer pricing (TP) purposes in cases involving a joint venture without majority control.
See MoreTurkey publishes transfer pricing General Communiqué No. 4
On 1 September 2020, the Turkish Revenue Administration has published transfer pricing General Communiqué No. 4 on disguised profit distribution in the Official Gazette No. 31231. The Communiqué explains information regarding new transfer pricing
See MoreSouth Africa: National Treasury publishes draft 2020 Tax Law Amendment Bills
On 31 July 2020, the National Treasury published the 2020 Draft Taxation Laws Amendment Bill, which includes a proposed change to the definition of âaffected transactionâ for transfer pricing purposes. The proposed amended definition would be
See MoreUkraine: Parliament approves draft law to implement BEPS provisions
On 16 January 2020, the Ukrainian Parliament approved draft laws on the improvement of the administration of taxes and elimination of certain inconsistencies in tax legislation (Law No 1209-1 and Law No 1210) to implement the Base Erosion and
See MoreUkraine: SFS explains about foreign exchange differences for transfer pricing purposes
Recently, the Ukraine State Fiscal Service (SFS) has explained about treatment of foreign exchange differences if controlled transactions meet the transfer pricing thresholds. Transactions are classified as controlled transactions if the annual
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