Canada releases consultation paper on reforming transfer pricing rules
On 6 June 2023, the Canadian Department of Finance issued a consultation paper on reforming and enhancing Transfer Pricing Rules. Budget 2021 announced the government’s intention to consult on Canada’s transfer pricing rules with a view of
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Brazil: Federal Senate approves OECD-aligned transfer pricing rules
On 10 May 2023, the Brazilian Federal Senate approved legislation addressing the new transfer pricing which was published on 29 December 2022. This approval is one of the last steps to implement a transfer pricing system in Brazil according to
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Australia: Federal Budget for FY 2023-24
On 9 May 2023, Mr. Jim Chalmers, the Australian Treasurer handed down Federal Budget for FY 2023-24, with some proposed changes to tax and superannuation laws. Many of the measures announced are subject to receiving royal assent and therefore not
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Luxembourg: Government submits draft bill on transfer pricing and general tax procedures
On 28 March 2023, the Luxembourg government submitted Bill No. 8186 to the Parliament. The bill includes changes in advance pricing arrangement (APA), mutual agreement procedure (MAP), compliance with transfer pricing documentation requirements, and
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Malta: CFR updates FAQs on DAC6
On 13 April 2023, the Maltese Commissioner for Revenue (CFR) updated “frequently asked questions” (FAQs) on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements (DAC6). Accordingly, the following questions
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Saudi Arabia: ZATCA approves amendment to the TP Bylaws
On 20 March 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) approved Decision No. 8-2-23 to amend the Transfer Pricing (TP) Bylaws. The approved amendments to the TP Bylaws in Saudi Arabia will expand the scope of the provisions to
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Brazil: Lower House passes transfer pricing reform measure
On 30 March 2023, the Brazilian Lower House of Congress adopted Measure No. 1,152 to overhaul its transfer pricing system that was introduced on 29 December 2022. In addition to introducing the arm's length principle into the Brazilian transfer
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Malta: CFR provides guidelines on DAC6 notification obligations for intermediaries
On 8 March 2023, the Maltese Commissioner for Revenue (CFR) provides guidelines in relation to the waiver from filing information in respect of a reportable cross-border arrangement (DAC6). Following the CJEU decision on 8 December 2022, Maltese
See MoreBrazil issues normative instruction establishing new transfer pricing regulations for 2023
On 24 February 2023, the Brazilian Federal Revenue Office published the Normative Instruction No. 2.132 which establishes the regulation of the taxpayer's choice to apply the new transfer pricing rules according to Provisional Measure (PM) No.
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Malta: CFR extends DAC6 annual notification deadline for non-disclosing intermediaries
On 17 February 2023, the Maltese Commissioner for Revenue (CFR) notified that the deadline for annual notification of cross-border arrangements (DAC6) by non-disclosing intermediaries is being extended. Accordingly, non-disclosing intermediaries
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Argentina: AFIP introduces new mandatory disclosure regime for international transactions
On 27 December 2022, Argentina's federal tax authority (AFIP) released General Resolution No.5306/2022, establishing a new mandatory disclosure regime for certain international transactions. It has replaced the previous mandatory reporting regime
See MoreBrazil issues new transfer pricing legislation to align with OECD transfer pricing guidelines
On 29 December 2022, the outgoing Brazilian President issued draft legislation MP 1.152 to align Brazil’s unique transfer pricing system with the OECD Transfer Pricing Guidelines. The news rule will be compulsory for 2024, for fiscal year 2023,
See MoreMalta implements formal transfer pricing rules
On 18 November 2022, Malta published Legal Notice 284 of 2022 in the Official Gazette implementing transfer pricing rules into Malta’s tax code. These rules shall apply for basis years commencing on or after 1 January 2024 in relation to any
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Ireland: Revenue updates guide to exchange of information under DAC6
On 26 September 2022, the Irish Revenue published an eBrief No. 175/22 on Guide to Exchange of Information. Accordingly. Tax and Duty Manual Part 35-01-01a (the Guide) under Council Directive 2011/16/EU, Ireland’s double taxation agreements and
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Poland releases ordinance on transfer pricing information
On 13 September 2022, the Polish Official Gazette released Ordinance Nos. 1923 and 1934, clarifying transfer pricing information in the scope of personal and corporate income tax. The ordinances include the following tax measures: Defining the
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Ireland: Revenue issues guidance on attribution of profits to a branch
On 7 September 2022, the Irish Revenue published an eBrief No. 166/22 on the attribution of profits to a branch. Accordingly, Tax and Duty Manual Part 02-02-04a has been issued to provide an overview and guidance in relation to the attribution of
See MoreSlovak Republic approves draft bill to amend transfer pricing rules
The government of the Slovak Republic has approved the draft law amending the Income Tax Act and the Act on Tax Administration. The amendments include following changes: implementation of rules on restriction of interest deduction in accordance
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Paraguay updates list of low-tax Jurisdictions
On 24 August 2022, the Paraguayan tax authority (SET) issued General Resolution No. 118/2022, concerning the Transfer Pricing Technical Study (ETPT) and a list of low-tax jurisdictions. The amended list of low-tax jurisdictions are
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