Ukraine reports 2023 transfer pricing adjustments results and penalty relief
On 22 February 2024, the State Tax Service of Ukraine published a release about the outcome of the transfer pricing adjustments in 2023. The release mentioned that from 1 August 2023 until the conclusion of martial law in Ukraine, taxpayers can
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Malaysia publishes surcharge FAQs related to transfer pricing adjustments
On 18 January 2024, the Inland Revenue Board of Malaysia (IRBM) published an FAQ list about surcharges for transfer pricing adjustments. The FAQ document is available on the transfer pricing guidance webpage. Under the Finance Act 2020, the tax
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Russia announces transfer pricing changes from 2024
On 27 November 2023, Russia issued Law No. 539-FZ in the Official Gazette, which outlines several amendments to the country’s transfer pricing regime. A summary of several key changes is outlined below: Secondary adjustments treated as
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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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Israel releases Guidance on MAP and APA procedures
On 17 August 2023, the Israel Tax Authority (ITA) released Tax Circular No. 1/2023, which provides guidance for mutual agreement procedure (MAP), and bilateral advance pricing agreement (APA) requests. The new circular replaces the guidance of
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Georgia adopts rules on Mutual Agreement Procedures (MAP)
The Ministry of Finance of Georgia recently published Decree No. 258 of July 2023, which approves the rules for the Mutual Agreement Procedures (MAP) under the Tax Treaties of Georgia or the provisions of the BEPS MLI. The rules encompass various
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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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Nigeria: FIRS releases new guidelines on mutual agreement procedures
On 23 May 2023, the Federal Inland Revenue Service (FIRS) of Nigeria has released Information Circular No. 2023/04 which includes new Guidelines on Mutual Agreement Procedure (MAP). The purpose of the guidelines is to provide guidance on how to
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Sri Lanka: IRD publishes MAP guidelines
On 8 May 2023, the Sri Lanka Inland Revenue Department (IRD) has published Mutual Agreement Procedure (MAP) guidelines. The guidelines provide several key aspects related to Mutual Agreement Procedure (MAP) requests in Sri Lanka. The guidelines
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Chile: Tax authority clarifies time limits for MAP requests
On 19 April 2023, Circular No. 19 was released by the Chilean tax authority. This circular modifies Circular No. 13, which was published on 18 March 2022, which provides guidance on the Mutual Agreement Procedures (MAP) under Chile’s tax treaties.
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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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Chile launches public consultation on MAP
The Internal Revenue Service (SII) of Chile has launched a public consultation on a draft circular that aims to clarify the 3-year deadline for submitting a mutual agreement procedure (MAP) request. The SII is accepting feedback from the public
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Malaysia: IRBM issues FAQs to clarify MAP guidelines
On 1 February 2023, the Inland Revenue Board of Malaysia (IRBM) has issued a list of frequently asked questions (FAQs) on the mutual agreement procedure (MAP) to provide further clarification to the 2017 MAP guidelines. In relation to the
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Greece amends corresponding adjustment provisions for Transfer Pricing
On 23 September 2022, Greece published Law No. 4972/2022 in the Official Gazette containing various tax measures including transfer pricing. The law amends an existing provision on transfer pricing adjustments upwards to provide for corresponding
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Dominican Republic: DGII Publishes general standard rule on MAP
On 30 August 2022, the Dominican Tax Authorities (DGII) issued a new general standard rule on Mutual Agreement Procedures (MAP) for Dispute Resolution under the country's tax treaties. The general rules introduced details for submitting MAP
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Singapore: IRAS Publishes Updated E-Tax Guide on GST TP Adjustments
On 3 August 2022, the Inland Revenue Authority of Singapore (IRAS) updated the GST-E Tax Guide on Transfer Pricing Adjustments (Third Edition). The e-Tax guide explains the GST treatment for adjustments on the transfer prices of transactions between
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Dominican Republic publishes resolution on inflation adjustments
On 20 July 2022, the Dominican Republic tax authorities published a Resolution (DDG-AR1-2022-00006) on multipliers and adjustments for the fiscal year closing in June 2022. The Resolution includes the following changes: Set the inflation
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Philippines issues MAP Guidelines
The Philippines Bureau of Internal Revenue (BIR) has published Revenue Regulations No. 10/2022 on mutual agreement procedure (MAP) guidelines and process for requesting MAP assistance. The MAP article in the Double Taxation Agreements or tax
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