| 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 new regime applies to companies, non-profit entities, trusts, mutual funds, and permanent establishments incorporated or resident in Argentina. See the story in Regfollower |
| Belarus | Main corporate income tax rate: On 4 January 2023, Belarus published Law No. 230-Z in the Official Gazette amending various tax measures. Accordingly, the income tax rate for corporations has been increased to 20% from 18% effective from 1 January 2023. See the story in Regfollower |
| Belgium | Restriction on interest deduction: On 12 January 2023, Belgium issued Circular 2023/C/8, which provides instructions on the application of the 30% of EBITDA interest deduction limitation in line with the EU Anti-Tax Avoidance Directive (ATAD). See the story in Regfollower |
| Colombia | Documentation-Timing and deadlines: On 16 December 2022, the Colombian Ministry of Finance Published Decree 2487 specifying deadline for transfer pricing (TP) documentation. Some of the key deadlines for companies depend on the last digits of the taxpayer’s tax number (NIT number). See the story in Regfollower |
| Croatia | Digital economy transactions-General: The OECD has announced that, on 15 December, Croatia has signed the Multilateral Competent Authority Agreement on Automatic Exchange of Information regarding Income from Digital Platforms. See the story in Regfollower |
| Germany | Digital economy transactions-General: Germany officially implemented new rules regarding the exchange of information related to income earned by sellers through digital platforms (DAC7), published in the Official Gazette on 28 December 2022. See the story in Regfollower |
| Ireland | CbC reporting requirement-General rule: On 25 January 2023, the Irish Revenue issued e-Brief No. 018/23 on country-by-country (CbC) reporting – data access & usage. Accordingly, Tax and Duty Manual Part 38-03-20 has been updated. See the story in Regfollower |
| Israel | CbC reporting requirement-General rule: On 8 December 2022, the Israel Tax Authority (ITA) has released guidelines and technical instructions for the filing of Country-by-Country (CbC) reports. Companies need to file their CbC report for the 2021 fiscal year by March 31, 2023. To file a Country-by-Country (CbC) report in Israel, companies must register in the HMA portal for automatic exchange of information. See the story in Regfollower |
| Liberia | Information exchange-Bilateral: On 24 January 2023, the OECD has updated its list of signatories for the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country Reports (CbCR), showing that Liberia joined the agreement on 1 June 2022. See the story in Regfollower |
| Malta | Digital economy transactions-General: On 20 January 2023, Malta issued Legal Notice 8 of 2023 in the Official Gazette. Accordingly, Malta implemented regulations on the exchange of information on income from digital platforms (DAC7). The regulations take effect starting from 1 January 2023. See the story in Regfollower |
| North Macedonia | Documentation-Timing and deadlines: North Macedonia proposed to amend the corporate income tax law including requirements to submit a transfer pricing report. Accordingly, TP report should be filed within 30 days upon request by the tax authority. The changes would become effective from 1 January 2023. See the story in Regfollower |
| Poland | Restriction on interest deduction: On 23 December 2022, the Polish Ministry of Finance published a notice in the official gazette, establishing base interest rates on a loan, credit or bond concluded between related parties. See the story in Regfollower |
| Singapore | Financial transactions-General: On 3 January 2023, the Inland Revenue Authority of Singapore (IRAS) published updated transfer pricing (TP) guidelines on indicative margin for related-party loans. See the story in Regfollower |
| Slovak Republic | Documentation-Requirement: The Slovak Ministry of Finance (MoF) has issued new guidelines to determine the content of transfer pricing (TP) documentation, effective for the tax period starting after 31 December 2022. See the story in Regfollower |
| South Africa | Application to intra-group services: On 17 January 2023, the South African Revenue Service (SARS) issued Interpretation Note 127 that explains how to calculate the taxable income of certain individuals or entities involved in international transactions, specifically in regard to loans within a group of companies. See the story in Regfollower Compliance with BEPS standards: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for South Africa on 1 January 2023. See the story in Regfollower |
| South Korea | Documentation-Requirement: On 23 December 2022, South Korea’s National Assembly approved the budget for 2023 providing exemption threshold for submitting information on international transactions from 1 January 2023. See the story in Regfollower |
| US | CbC reporting requirement-General rule: On 5 January 2023, the Internal Revenue Service invited the general public and other federal agencies to take this opportunity to comment on Form 8975 (CbC report) and Schedule A (Form 8975). Written comments should be submitted on or before March 6, 2023. See the story in Regfollower |
