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 they should be applied.
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Dominican Republic CbC reporting requirement-Deadlines: On 12 January 2024, the Directorate General of Internal Revenue (DGII) in the Dominican Republic released Notice 01-2024, notifying the public that the reporting portal for Country-by-Country (CbC) reports, known as the Portal Reporte País por País, is now accessible via the CbC report main page.
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Germany Digital economy transactions: On 5 January 2024, the German Federal Tax Office declared temporary regulations regarding the reporting requirements outlined in DAC7 for the 2023 reporting cycle, extending the initial deadline until 31 March 2024.
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India Safe harbour-Rule: On 19 December 2023, the Central Board of Direct Taxes (CBDT) in India announced significant changes to the safe harbor rules for intragroup financing arrangements.
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Malta Scope of transfer pricing rules: On 19 January 2024, Malta’s Commissioner for Revenue published Guidelines in relation to the Transfer Pricing Rules. These guidelines will be regularly reviewed and in the case of any changes, the revised version of the guidelines will be published on the Malta Tax and Customs Administration website.
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Singapore Information exchange-Multilateral: On 19 January 2024, the Inland Revenue Authority of Singapore (IRAS) updated the list of jurisdictions participating under the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports.
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Information exchange-Multilateral: On 12 January 2024, the Inland Revenue Authority of Singapore (IRAS) published the third edition-e-Tax Guide on common reporting standard. The Common Reporting Standard (CRS) is a globally accepted standard designed for the automatic exchange of financial account information between jurisdictions to enhance the fight against tax evasion and ensure compliance with tax regulations.
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South Africa APAs-General rules: On 22 December 2023, the South African Revenue Service officially published the 2023 tax acts introducing the legislative provisions for the establishment of an advance pricing agreement (APA) program. APAs will apply for up to a maximum of five consecutive years of assessment, commencing on the day after the end of the year of assessment in which the associated APA application is received by the Commissioner.
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Switzerland Scope of transfer pricing rules: On 23 January 2024, the Swiss Federal Tax Administration published the updated Transfer Pricing Guide. The main provisions of the guide include the overview of the arm’s length principle, the overview of comparability analysis, overview of the transfer pricing methods and the overview of the transfer pricing documentation.
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Ukraine CbC reporting requirement: The State Tax Service of Ukraine announced on 11 January 2024, the introduction of Country-by-Country (CbC) reporting for parent companies of international groups of companies, marking the first implementation of such reporting in the country. Ukraine’s CbC reporting requirements are set to apply from the 2022 reporting fiscal year.
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UK APAs-General rules: In 2022/23 HMRC agreed 15 transfer pricing-related advance pricing agreements (APAs). The average time to reach an agreement was 45.5 months.
MAP: A total of 131 transfer pricing related mutual agreement procedure (MAP) cases were resolved in 2022/23, the same number as in the previous year, and the average time to resolve a case was 28.4 months. During the year 99 new transfer pricing MAP cases were accepted.
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