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
See MoreGermany 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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Switzerland releases Q&A guidance on application of transfer pricing rules
On February 23, 2024, the Swiss Federal Tax Authorities (SFTA) published the Q&A guidance regarding the application of transfer pricing regulations in Switzerland. This guidance clarifies the application of the arm's-length principle and the
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Norway issues new guidance on transfer pricing reporting requirements for 2024
On 8 February 2024, the Norwegian Tax Administration (NTA) released a guidance regarding the amendments of the transfer pricing disclosures in tax returns for organizations, due by 31 May 2024 for the fiscal year ending in 2023. The guidance
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UK: HMRC publishes transfer pricing guidance on accurate delineation of actual transactions and analysis of risk
On 30 January 2024, the UK HMRC revised its transfer pricing operational guidance by including a new section on the accurate delineation of actual transactions and the analysis of risk. The updated transfer pricing operational guidance is
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Belarus modifies transfer pricing rules
On 27 December 2023, Belarus announced that it had made amendments to its transfer pricing rules. The new transfer pricing provisions are outlined in Law No. 327-Z of 27 December 2023, which went into effect on 1 January 2024. The new regulations
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Malta issues guidelines for transfer pricing rules
On 19 January 2024, Malta's Commissioner for Revenue published Guidelines in relation to the Transfer Pricing Rules. These guidelines are issued in terms of Article 96(2) of the Income Tax Act (Chapter 123 of the Laws of Malta) and are to be read in
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