Belgium: Constitutional court revokes several federal and regional DAC6 legislation
On January 11, 2024, the Belgian Constitutional Court released a statement regarding four judgments related to legislation passed by the Federal government, the Walloon region, Brussels, and the French Community. These judgments pertain to the
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Indonesia releases revised guidelines for transfer pricing
On 29 December 2023, Indonesia’s Minister of Finance (MoF) released the revised transfer pricing guidelines Regulation No. 172 of 2023 (PMK-172). The updated and consolidated transfer pricing regulations in various chapters, such as: General
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Kazakhstan’s Transfer Pricing Legislative Amendments 2023
Kazakhstan is undergoing a pivotal transformation in its transfer pricing framework, marked by the Majilis' approval of substantial amendments to the existing legislation. The aim is to curb revenue losses, prevent capital outflow, and align with
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Brazil tax reform brings challenges to service sectors
The new Brazilian transfer pricing rules align with the OECD standard and are a radical change to the analysis of intra-group transactions, and offer several implementational challenges. Besides, the tax reform (PEC 45/2019) is being discussed in
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France: Tax authority updates transfer pricing guidelines for SMEs
On 22 November 2023, the French tax authority published an updated transfer pricing guide for small and medium-sized enterprises (SMEs). The guide covers a wide range of topics, including the concept of transfer pricing, the arm's length principle,
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Australia: ATO updates guidelines on central management and control test of residency
The Australian Taxation Office (ATO) has released updated guidelines that give foreign companies greater certainty about the compliance under the central management and control test. For better clarification to foreign companies regarding their
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Saudi Arabia: ZATCA releases drafts of new income tax and tax procedural laws for public consultation
On 25 October 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued drafts of a new Income Tax Law and Zakat and Tax Procedures Law for public consultation. The public consultation period for comments on the drafts is open until 25
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Italy: Revenue agency issues draft guidelines on investment management transfer pricing
On 20 October 2023, the Italian Revenue Agency issued the draft transfer pricing guidelines for implementing the Investment management exemption regime (IME). The draft was in public consultation until 3 November 2023. The IME was introduced by
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UAE: FTA releases transfer pricing guide
On 23 October 2023, the Federal Tax Authority (FTA) of the United Arab Emirates (UAE) released the Transfer Pricing Guide. This guide is designed to provide general guidance on the Transfer Pricing regime in the UAE with a view to making the
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Egypt releases explanatory instructions on transfer pricing reporting obligations
On 19 September 2023, the Egyptian Tax Authority issued Explanatory Instruction No. 78 introducing mandatory transfer pricing reporting obligations for related party transactions. Accordingly, the Tax Authority has set deadlines for submitting
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France: FTA publishes update guidelines on DAC6
On 13 September 2023, the French tax authorities (FTA) revised their DAC 6 administrative guidelines in order to provide further clarification on hallmark D.1.b. This particular hallmark relates to the automatic exchange of information and
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Austria: Ministry of Finance releases DAC6 reporting guidelines
On 12 September 2023, the Austrian Ministry of Finance published an updated guidance on the explanation and application of the rules of DAC6 in Austria. This update is a practical guide to understanding EU-MPfG compliance, based on questions and
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Ecuador: SRI gazettes resolution amending transfer pricing rules
On 13 September 2023, Ecuador's Internal Revenue Service (SRI) issued Resolution No. NAC-DGERCGC23-00000025, which modifies the transfer pricing rules. The resolution includes following measures: Taxpayers who have conducted transactions with
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Kenya: KRA publishes draft transfer pricing rules 2023
On 4 September 2023, the Kenya Revenue Authority (KRA) published draft income tax (Transfer Pricing) rules 2023 for public comment. The income tax rules are designed to harmonize with the provisions of the Finance Act 2022, which introduced
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Pakistan: FBR issues circular on finance Act changes
On 26 July 2023, the Federal Board of Revenue in Pakistan (FBR) issued Circular No. 2 of 2023, providing an explanation of the income tax amendments introduced through the Finance Act of 2023. The circular elaborates on the following
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Luxembourg: Tax Authority updates FAQs on DAC6
On 30 June 2023, the Luxembourg Tax Authority updated the frequently asked questions (FAQs) concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). The latest update clarifies the following measures:
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Germany: BMF issues updated transfer pricing guidelines
On 6 June 2023, the German Federal Ministry of Finance (BMF) has published updated transfer pricing administrative guidelines. The guidelines focus on two main areas: The application of the arm's length principle in accordance with the OECD
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Brazil: President signs OECD-aligned transfer pricing rules
On 14 June 2023, the president Luiz Inácio Lula da Silva signed the Law No. 14,596 adopting Provisional Measure No. 1,152, which enacts significant changes to the Brazilian transfer pricing system that is aligned with the guidelines provided by the
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