South Korea: NTS updates MAP guidance
On 30 June 2022, South Korea’s National Tax Service (NTS) has issued updated Mutual Agreement Procedure (MAP) guidance on the official website. The guidance prescribes the following key areas: Overview of MAP; Application of MAP;
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Hungary: Finance minister presents 2023 budget bill to parliament
On 22 June 2022, the Hungarian finance minister submitted the 2023 Budget Bill in parliament providing following tax measures related to transfer pricing changes. The bill proposes to revise the regulation of the application of the interquartile
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India: CBDT updates guidance on MAP
On 10 June 2022, India's Central Board of Direct Taxes (CBDT) issued comprehensive updated guidance on the Mutual Agreement Procedure (MAP) and related matters. The guidance supplements the previous guidance published on 7 August 2020 and addresses
See MoreDominican Republic: DGII invites comments on the draft MAP rule
On 26 May 2022, the Dominican Republic's Directorate General of Internal Revenue (DGII) launched a public consultation on a draft general standard (rules) on Mutual Agreement Procedures (MAP) for dispute resolution under the country's tax treaties.
See MoreAustria publishes guidance on MAP procedures under DTAs, MLI, and EU Laws
On 6 May 2022, the Ministry of Finance issued new guidelines on mutual agreement and arbitration procedures (MAP) under the Austrian double taxation agreements, the EU Arbitration Convention, the BEPS Multilateral Instrument (MLI), and the EU Tax
See MoreUK: Transfer Pricing and Diverted Profits Tax Statistics
On 28 April 2022 HMRC published the latest set of statistics relating to transfer pricing and the diverted profits tax. The latest release contains data up to end of the 2020/21 tax year. HMRC is anxious to reduce the amount of the tax gap,
See MoreOECD: Peer Review Reports on Making Tax Dispute Resolution More Effective
On 14 April 2022 the OECD published a further set of peer review reports under BEPS Action 14 which is concerned with making tax dispute resolution mechanisms more effective. These reports set out the results of assessments under stage two of the
See MoreJordan: ISTD publishes transfer pricing and CbC Notification forms
Recently, the Jordan Income and Sales Tax Department (ISTD) has published new transfer pricing and country-by-country (CbC) Notification forms (Arabic language) in line with executive instructions No. 3 of 16 September 2021. Transfer pricing
See MoreOECD: Second Stage Peer Review of Guernsey under BEPS Action 14
On 24 January 2022 the OECD issued the stage 2 peer review report assessing Guernsey’s compliance with the minimum standard under Action 14 of the project on base erosion and profit shifting (BEPS). Action 14 is concerned with making tax dispute
See MoreItaly confirms VAT treatment of TP adjustments
On 30 December 2021, the Italian Revenue Agency has published Ruling No. 884 clarifying the VAT treatment of transfer pricing (TP) adjustments. In the case at issue in Ruling Answer No. 884/2021, a resident company made a number of TP
See MoreIreland: Revenue updates guidelines for requesting MAP assistance
On 23 December 2021, the Revenue published an eBrief No. 236/21 on the updated Manual for requesting Mutual Agreement Procedure (“MAP”) assistance in Ireland. The Guide has been updated to incorporate Council Directive (EU) 2017/1852 of 10
See MoreFinland: Parliament adopts the law on transfer pricing adjustment
On 9 December 2021, the Finnish Parliament has approved the amendment to the transfer pricing adjustment provision, (VML Section 31) of the Tax Procedure Act (VML). On 16 December 2021, the President signed the law, the amendment will take effect
See MoreSpain: Tax authority publishes a guide and Q&As on MAP
On 19 November 2021, the tax authorities have issued a guide and questions and answers (Q&As) on mutual agreement procedures (MAPs) to provide taxpayers with guidance on the main aspects of MAP. The Q&As clarified that the Spanish
See MoreNigeria issues new procedural rules for tax appellate tribunal
Recently, the Minister of Finance, Budget and National Planning issued new Tax Appeal Tribunal (Procedure) Rules 2021. The Rules replace the 2010 Rules and are intended to guide the practice and procedure of Tax Appeal Tribunal (“TAT“)
See MoreSingapore: IRAS updates e-Tax Guide on DTA to address arbitration procedure
On 23 October 2021, the Inland Revenue Authority of Singapore (IRAS) issued an updated edition of its e-tax guide on “avoidance of double taxation agreements” to add guidance on arbitration provisions in Singapore’s double tax
See MoreTurkey issues Regulations on mutual agreement procedures (MAP)
On 26 October 2021, Turkey has published Law No. 7338 on Certain Amendments on Tax Procedural Law and Certain Laws in the Official Gazette which clarifies provisions with respect to the domestic application of the mutual agreement procedure
See MoreRussia: MOF publishes Tax Policy guidelines for 2022-2024
On 27 September 2021, the Ministry of Finance has reportedly issued the tax policy guidelines for 2022-2024, which includes the following tax measures: The introduction of new corporate and individual tax rules for taxing digital asset
See MoreTurkey: Parliament members submit a new Tax Bill to the Parliament
On 1 October 2021, Turkish Parliament members have submitted a new Tax Bill to the Parliament which includes tax filing periods, tax exemptions, and incentives. The key corporate tax measures of the Bill are: In the reduced corporate tax
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