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 Prevent Base Erosion and Profit Shifting (MLI).
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Azerbaijan Compliance with BEPS standards: On 16 December 2022, the Organization for Economic Cooperation and Development (OECD) announced that Azerbaijan joins the inclusive framework on Base Erosion and Profit Shifting (BEPS).
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Belgium Time limit and Statute of limitation: On 30 November 2022, Belgium published the Law of 20 November 2022 on amending the statutes of limitations periods and financial provisions in the Official Gazette. The statute of limitations and appeal changes generally apply from 1 January 2023, except for the appeal period extension for supplementary assessments, which applies from 1 January 2025.
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Brazil OECD Guidelines: On 29 December 2022, the outgoing Brazilian President issued draft legislation MP 1.152 to align Brazil’s unique transfer pricing system with the OECD Transfer Pricing Guidelines. The new legislation is consistent with the OECD transfer pricing guidelines however it does not specifically mention the OECD TPG.
Related party definition: The definition of related parties has been broadened where it considers not only conventional controlled transactions but also uncontrolled transactions when one of the parties is resident or domiciled in a country that taxes income at a rate lower than 17% or zero.
Penalties for documentation failure: Penalties for non-compliance regarding transfer pricing documentation have been introduced which is range from BRL 20,000 (approx. USD 4,000) to BRL 5,000,000 (approx. USD 1,000,000).
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Hungary Documentation-Requirement: On 9 December 2022, the Hungarian Ministry of Finance issued a draft transfer pricing decree detailing a new transfer pricing reporting obligation. Accordingly, taxpayers are required to prepare a transfer pricing report on a transaction basis or on a consolidated transaction basis.
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Ireland OECD Guidelines: On 15 December 2022, the President of Ireland signed the Finance Bill 2022 into Law. The Finance Act updates the definition of transfer pricing guidelines to reference the OECD’s most recent guidelines published in January 2022.
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Luxembourg Special rules for hybrid instruments or entities: On 15 December 2022, the Luxembourg Parliament approved the budget law 2023. The draft budget law amends Article 168 quater of the Luxembourg Income Tax Law (LITL) regarding reverse hybrid entity rule in line with the ATAD 2 directive applicable from 1 January 2022.
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Morocco CbC reporting requirement-General rule: On 16 December 2022, the Moroccan tax authority published an announcement, which temporarily suspending the requirement to file a country-by-country (CbC) report for companies that are part of multinational enterprises (MNEs) operating in Morocco.
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Serbia Restriction on interest deduction: On 16 December 2022, the Serbian Ministry of Finance has published the Rulebook on arm’s Length interest rates applicable for 2022 that applies on related parties’ loans. Rulebook comes into force on 24 December 2022.
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Slovak Republic CbC reporting requirement-General rule: The amendment to the Accounting Act No. 407/2022 implements EU Directive No. 2021/2201 requiring qualifying multinational enterprises (MNEs) doing business in the EU to publicly disclose certain information on a CbC reports, effective for accounting periods beginning on 22 June 2024 or later.
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South Africa Compliance with BEPS standards: On 1 December 2022, the South African National Treasury publishes a media statement on Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“Multilateral Instrument” or “BEPS MLI”).
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Spain CbC reporting requirement-General rule: On 22 December 2022, the Spanish government published the legislation implementing the European Union (EU) Directive on Public Country-by-Country (CbC) Reporting (CbCR).
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UAE Scope of transfer pricing rules: On 9 December 2022, the UAE Ministry of Finance (MoF) released the Federal Decree-Law No. 47 of 2022 on business taxation to enact a new Corporate Tax Law in the UAE. Accordingly, transfer pricing rules apply to UAE businesses that have transactions with Related Parties and Connected Persons, irrespective of whether the Related Parties or Connected Persons are located in the UAE mainland, a Free Zone or in a foreign jurisdiction.
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UK Master file/Local file: On 21 December 2022 the UK issued for consultation the draft regulations on Transfer Pricing Documentation, inviting comments from interested parties by 31 January 2023. The draft statutory instrument would require multinationals operating in the UK with turnover of EUR 750 million or more to keep a master file and local file in line with the OECD Transfer Pricing Guidelines.
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US Information exchange-Bilateral: On 7 December 2022, the Internal Revenue Service (IRS) published a joint statement with the competent authority of the United States of America and the competent authority of the French republic on the implementation of the spontaneous exchange of country-by-country reports for fiscal years beginning in 2022 and 2023.
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