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 Regfollower |
Australia | Restriction on interest deduction: On 17 November 2022, the Australian Taxation Office (ATO) published an updated version of Practical Compliance Guideline (PCG) 2017/2 related to the eligibility criteria for applying simplified transfer pricing record keeping options for low level related party inbound and outbound loans. See the story in Regfollower |
Belgium | Audits-Time limit and Statute of limitation: On 10 November 2022, the Belgian parliament approved the law amending the statutes of limitations periods. A standard 6-year statute of limitations is set in specific cases, such as requirements to submit a local file, requirements to submit a CbC report. See the story in Regfollower |
Costa Rica | Filing deadlines: On 9 November 2022, Costa Rica published the Resolution No.DGT-R-033-2022 regarding further extension of deadline for filing informative returns for dormant companies. Previously, it was extended to 15 March 2022. Then it was rescheduled to 15 November 2022, and now it will be April 2023. See the story in Regfollower |
Germany | Information exchange-Bilateral: On 23 November 2022, the German Ministry of Finance published a draft bill providing an update list of jurisdictions participating under the MCAA on the exchange of CbC reports. Accordingly, Germany will exchange the reports with State of Barbados for the next scheduled exchange date of 31 March 2023. See the story in Regfollower Information exchange-Bilateral: On 4 November 2022, the German Upper House of Parliament (Bundesrat) approves bill No. 567/22 for consideration to ratify the competent authority agreement (CAA) on the exchange of country-by-country (CbC) reports with the US. See the story in Regfollower |
Hungary | APAs-General rules: On 18 October 2022, Hungarian Ministry of Finance has submitted a draft legislation to the Parliament proposing the amendments of advance pricing arrangements (APAs) and introduction of public CbC reporting. See the story in Regfollower |
Indonesia | Information exchange-Multilateral: On 2 November 2022, the Indonesian General Directorate of Taxes (DGT) published a list of jurisdictions participating in the automatic exchange of Country-by-Country (CbC) reports and with which a qualifying competence authority agreement (QCAA) is in force. See the story in Regfollower |
Kenya | Information exchange-Multilateral: On 9 September 2022, Kenya signed the multilateral competent authority agreement on the exchange of Country-by-Country Reports (CbC MCAA). The CbC reporting requirements apply in Kenya from 2022 for MNE groups with gross turnover of KES 95 billion and above. See the story in Regfollower |
Malta | Scope of 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. TP rules will apply to associated enterprises having directly or indirectly more than 75% of participating rights, and 50% for constituent entities of MNEs within the scope of CbC reporting. See the story in Regfollower |
Mexico | Compliance with BEPS standards: On 22 November 2022, the Mexican President approved a Decree for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). See the story in Regfollower |
Singapore | CbC reporting requirement-General rule: On 31 October 2022, the Inland Revenue Authority of Singapore (IRAS) published the fourth edition of its e-Tax Guide concerning country-by-country (CbC) reporting. See the story in Regfollower |
UK | OECD Guidelines: On 9 November 2022, the UK Official Gazette published Statutory Instrument No. 2022/1147, on transfer pricing (TP) guidelines. The statutory instrument outlines the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. See the story in Regfollower |
Ukraine | Information exchange-Multilateral: On 4 November 2022, the Ukrainian State Tax Service (STS) announced that Ukraine joined the Multilateral Competent Authority Agreement (MCAA) on the exchange of country-by-country reports (CbCR) on 3 November 2022. See the story in Regfollower |
Related Posts
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
Read MoreTransfer 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
Read MoreTransfer 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
Read MoreTransfer 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
Read MoreTransfer 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
Read MoreTransfer 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
Read More