Ecuador rejects OECD Pillar One Amount B safe harbour in new SRI circular
Ecuador’s Internal Revenue Service (SRI) has clarified that the OECD’s Pillar One – Amount B framework has not been adopted in the country, reaffirming that taxpayers must continue to apply existing domestic transfer pricing rules to routine
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India extends transfer pricing safe harbor rules to FY 2024-25, updates filing deadline for international transactions
India's Central Board of Direct Taxes (CBDT) has released Notification No. 124/2024 outlining the Income Tax (Tenth Amendment) Rules, 2024 on 29 November 2024. According to the amendment, the transfer pricing safe harbor rules under Rule 10TD of
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UK launches consultation on safe harbour anti-arbitrage rule transition to domestic law
The UK Treasury released draft legislation for consultation on implementing the transitional safe harbour anti-arbitrage rule. This initiative ensures the rule aligns with the OECD's G20 Inclusive Framework's December 2023 Administrative
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Italy announces decree on Pillar Two transitional safe harbour rules
Italy’s Ministry of Finance announced the ‘TSH decree’, which was published in the official gazette on 28 May, 2024. This decree implements the Pillar Two transitional safe harbour (TSH) rules, as stipulated in Article 39 of Legislative
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Australia: ATO releases discussion paper on thin capitalization rules for foreign bank branches
On 17 April 2024, the Australian Taxation Office (ATO) published a discussion paper regarding the safe harbor formula for calculating the minimum capital requirements for inward investing deposit-taking institutions (ADIs) under the thin
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Greece proposes new law to implement EU minimum tax rules
On 23 February, 2024, the Greek Ministry of Finance initiated a public consultation on a proposed bill aiming to incorporate the OECD’s Pillar Two Model Rules, as outlined in the EU Minimum Tax Directive. This draft bill is currently open for
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Poland announces base interest rates for related party debt for 2024
On 3 January 2024, Poland’s tax authority published a release related to a notice on the base interest rates and margins for the safe harbor simplification for loan, credit, or bond transactions between related parties in 2024. The safe harbor
See MoreIndia: CBDT updates safe harbor rules for intragroup financing
On 19 December 2023, the Central Board of Direct Taxes (CBDT) in India announced significant changes to the safe harbor rules for intragroup financing arrangements. These updates, outlined in Notification No. 104/2023, will take effect on 1 April
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Germany: Bundesrat approves secondary credit market promotion Act
On 14 December 2023, upper house of parliament (Bundesrat) granted approval to the Secondary Credit Market Promotion Act. The Act had already received approval from the German Bundestag (lower house of parliament) on 13 December 2023 and is
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India: CBDT extends transfer pricing Safe Harbor Rules
On 9 August 2023, the Central Board of Direct Taxes (CBDT) issued a Notification No. 58/2023, to extend the applicability of the transfer pricing safe harbor rules. The extension applies for the financial year 2022-23 and 2023-24 assessment years.
See MoreMexico: Executive Branch submits 2022 economic proposal to Congress
On 8 September 2021, the Mexican Executive Branch has submitted Economic Package for the fiscal year 2022 including a proposal of Tax Reform. The proposed 2022 Tax Law clarifies income tax law, value-added tax (VAT) law, excise tax (duty)
See MoreIndia: Central Board of Direct Taxes (CBDT) publishes finance act 2020
On 27 March 2020, the Central Board of Direct Taxes (CBDT) published the Finance Act 2020 that includes measures announced as part of the Union Budget 2020-2021 and others. The measures of the Finance Act generally apply from 1 April 2020 (or
See MoreIsrael: Tax Authority publishes Circulars regarding transfer pricing issues
The tax authorities (ITA) have recently published final versions of two professional Circulars, entitled Circular 11/2018 and Circular 12/2018, stating the ITA's expected profit levels for marketing services and for low-risk distributorship
See MoreAustralia: Taxation Ruling 2014/8 introduces by the Australian Taxation Office (ATO)
Taxation Ruling 2014/8 gives outlines on what needs to be included in the documentation if the taxpayer is to meet the standard of a "reasonably arguable position" and avoid penalties, and sets out five key questions for preparation of
See MoreAustralia – Reduces safe harbor for thin capitalization
Australia recently reduced the safe harbor rule for thin capitalization limit from 75% to 60%, corporate groups may want to consider what steps to take with respect to their thin capitalization positions. With effect from 1 July 2014 the permitted
See MoreIndia – CBDT Releases Drafts on Transfer Pricing Safe Harbor Rules
India’s Central Board of Direct Taxes (CBDT) released draft transfer pricing “safe harbor” rules as part of an initiative by the government to reduce the number of transfer pricing audits and protracted disputes on 14th August 2013,. Under the
See MoreIrish Revenue announces transfer pricing compliance monitoring approach
On 6 December 2012 it was published that the Irish Revenue released guidance on 26 November 2012 setting out how they are proposing to monitor transfer pricing compliance in accordance with Part 35A of the Taxes Consolidation Act 1997 The guidance
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