Netherlands updates low-tax and non-cooperative jurisdictions list for 2025
The Netherlands has revised its lists of low-tax and non-cooperative jurisdictions for tax purposes, announcing the removal of Antigua and Barbuda, Belize, and the Seychelles. The lists are used for Dutch tax rules, targeting jurisdictions with
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Brazil: Revenue authority publishes updated guidance on commodities transfer pricing
Brazil’s revenue authority (Receita Federal) has issued new guidelines for Normative Instruction RFB No. 2246 of 30 December 2024, outlining rules for companies regarding the management of transfer pricing for transactions that involve commodities
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OECD introduces new tools to simplify transfer pricing (Amount B)
The OECD has announced the launch of new tools to streamline the implementation of Amount B under Pillar One aimed at simplifying transfer pricing rules. Amount B under the Two-Pillar Solution to Address the Tax Challenges of the Digitalising
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Georgia amends transfer pricing regulations for 2025
Georgia’s Ministry of Finance has announced that it has amended its international controlled transaction regulations through Order No. 331 (issued on 2 October 2024) to align with the latest OECD Transfer Pricing Guidelines. The amendment also
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US: Treasury, IRS clarify stance on OECD’s simplified transfer pricing rules
The US Treasury Department and the Internal Revenue Service (IRS) released Notice 2025-04, “Application of the Simplified and Streamlined Approach under Section 482”, on 18 December 2024, clarifying the US government’s stance on using the
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Germany: Fourth Bureaucracy Relief Act updates transfer pricing documentation requirements
The Fourth Bureaucracy Relief Act, which goes into effect on 1 January 2025, brings major updates to transfer pricing documentation requirements in Germany. This latest amendment brings the following changes: Transfer pricing documentation
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Poland consults updated low-tax jurisdictions list, removes Andorra
Poland’s Ministry of Finance has initiated a public consultation on a proposed legislation that identifies countries and territories involved in harmful tax practices, classifying them as low-tax jurisdictions. The bill proposes to remove
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Brazil consults commodity transfer pricing
Brazil's revenue authority has launched a public consultation on a proposed amendment to its transfer pricing rules on 27 November 2024. The proposed amendment concerns Normative Instruction RFB No. 2,161 of September 28, 2023, addressing
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Ireland approves new global tax reform rules
Ireland's parliament has passed a bill simplifying transfer pricing for marketing and distribution and amending global minimum tax rules on 6 November 2024. This legislation was enacted as part of the Finance Bill 2024, which was approved by both
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Germany passes Fourth Bureaucracy Relief Act, cuts accounting document retention and updates transfer pricing rules
Germany’s Federal Council (Bundesrat) passed the Fourth Bureaucracy Relief Act on 18 October 2024 following its approval by the Bundestag (lower house of parliament) on 26 September 2024. One key aspect of the Act is that it reduces
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Ukraine clarifies corporate tax rules for German entities under transfer pricing provisions
The Ministry of Finance of Ukraine has issued a clarification concerning the corporate taxes of the Federal Republic of Germany and their relevance to Ukrainian tax law, particularly in the context of transfer pricing regulations on 30 September
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Denmark: 2024-25 legislative plan proposes updates to minimum tax, transfer pricing to match OECD rules
Denmark's government announced the legislative programme for the parliamentary year 2024-25 on 1 October 2024. The bill follows up on the government platform "Responsibility for Denmark" from December 2022 and the agreement on "A Stronger Business
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Chile passes tax compliance bill with income, VAT, transfer pricing measures
Chile’s Senate has approved the Tax Compliance Bill on 24 September 2024, which will be presented to the Lower House for final approval. The newly approved tax measures include modifications to the general anti-avoidance rule (GAAR), statute of
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Russia: FTS issues new transfer pricing reporting requirements
Russia's Federal Tax Service (FTS) has introduced new guidelines requiring detailed disclosure of the price formation chain in controlled transactions for transfer pricing purposes. According to Guidance Letter ZG-2-13/11134, issued on 2 August
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New Zealand issues Commissioner’s Statement on withholding in transfer pricing
The New Zealand tax authority released the Commissioner's statement (CS) 24/02: Withholding obligations arising in relation to transfer pricing arrangements on 30 August 2024. CS 24/02 details the Commissioner's stance and operational strategy
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Ecuador updates transfer pricing report guideline, introduces new penalties
The Internal revenue service (SRI) has issued “Resolution No. NAC-DGERCGC24-00000020” in the Ecuadorian Official Gazette on 28 May, 2024, which outlines details of the transfer pricing annex concerning related party transactions and the
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Slovak Republic releases 2023 transfer pricing documentation guidelines
Slovak Republic's Ministry of Finance has issued guidelines (MF/020061/2022-724) outlining the requirements for transfer pricing documentation for 2023. These guidelines categorise transfer pricing documentation into three types: Full-scope
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Latvia revises domestic list of tax-free or low-tax jurisdictions
On 28 February 2024, the Latvia Ministry of Finance released the updated domestic list of tax-free or low-tax jurisdictions. The renewed list went into effect on 1 March 2024. In the updated list, Latvia removed Belize, Bahamas, Seychelles, Turks
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