Transfer Pricing Brief: February 2024
Australia Special rules for hybrid instruments or entities: The Australian Taxation Office (ATO) published guidance on the hybrid mismatch rules. The guidance explains why hybrid mismatch rules exist, how hybrid mismatch rules work and when
See More
Transfer Pricing Brief: January 2024
Algeria Transfer pricing information return: Algeria published the Supplementary Finance Law for 2023 in the Official Gazette. A new transfer pricing declaration obligation has been introduced, requiring taxpayers to submit an online transfer
See More
Transfer Pricing Brief: December 2023
Australia Restriction on interest deduction: On 28 November 2023, the Australian government released the amendments and a supplementary explanatory memorandum to the interest limitation rules within the Treasury Laws Amendment (Making
See More
Transfer Pricing Brief: November 2023
Australia Documentation: The Australian Tax Office (ATO) has announced that taxpayers with CbCR obligations for the year ending 31 December 2022 will now have until 31 January 2024 to submit their reports. This extension applies to the CbC
See More
Transfer Pricing Brief: October 2023
Armenia Compliance with BEPS standards: On 25 September 2023, Armenia deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI). See the story in
See More
Transfer Pricing Brief: September 2023
Australia Audit risk assessment: The Australian National Audit Office (ANAO) is conducting a performance audit to evaluate the efficiency of the Australian Taxation Office’s (ATO) transfer pricing (TP) management concerning loans between
See More
Transfer Pricing Brief: August 2023
Cyprus Local file: On 6 July 2023, the Cyprus Tax Department released a new circular (6/2023) entitled “Simplification measures for persons exempt from the obligation to maintain a Cyprus local file”. The Circular clarifies that persons
See More
Transfer Pricing Brief: July 2023
Brazil Scope of transfer pricing rules: On 14 June 2023, the president 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
See More
Transfer Pricing Brief: June 2023
Bolivia Filing deadlines: On 28 April 2023, the Bolivian National Tax Service published a Resolution No. 102300000014 extending the corporate income tax (IUE) reporting deadline for the tax year ending 31 December 2022 to 31 May 2023. See
See More
Transfer Pricing Brief: May 2023
Algeria Filing deadlines: The Algerian Directorate General of Taxes (DGI) has extended the deadline for filing corporate tax returns to 31 May 2023 for the tax year 2022. See the story in Regfollower Brazil Scope of transfer pricing
See More
Transfer Pricing Brief: April 2023
Australia Restriction on interest deduction: On 16 March 2023, the Australian Treasury issued the Exposure Draft on the earnings before interest, taxes, depreciation, and amortization interest limitation rules (EBITDA). Consultation closes on
See More
Transfer Pricing Brief: March 2023
Cyprus Documentation-Local file/Master file: On 10 February 2023, the Cyprus Tax Department published a set of Frequently Asked Questions (FAQs) aiming to clarify certain provisions of the new transfer pricing rules approved in June 2022 with
See More
Transfer Pricing Brief: February 2023
Argentina Scope of transfer pricing rules: 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. The
See More
Transfer Pricing Brief: January 2023
Austria Compliance with BEPS standards: On 30 November 2022, the Austrian Council of Ministers approved the extension of the application on existing tax treaties under the Multilateral Convention to Implement Tax Treaty Related Measures to
See More
Transfer Pricing Brief: December 2022
Argentina Compliance with BEPS standards: On 8 November 2022, the Argentine Commission on Foreign Affairs accepted a bill to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). See the story in
See More
Transfer Pricing Brief: November 2022
Azerbaijan Information exchange-Bilateral: On 26 October 2022, the President of the Republic of Azerbaijan published a law ratifying the Inclusive Framework on Base Erosion and Profit Shifting (BEPS), which was approved by the President on 11
See More
Transfer Pricing Brief: October 2022
Armenia Compliance with BEPS standards: On 14 September 2022, the Armenian Parliament (National Assembly) approved draft Bill No. K-294 for ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
See More
Transfer Pricing Brief: September 2022
Australia Local file-General rule: On 9 August 2022, the Australian Taxation Office (ATO) updated guidance on the Local and Master file for 2022 along with instructions. The guidance applies to reporting periods beginning on or after 1
See More