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 guidelines provided by the OECD.
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Chile Transfer pricing information return: On 20 June 2023, the Chilean tax authority (SII) issued Resolution No. 70 that provides an extension of three months to taxpayers who were required to submit their transfer pricing returns between 1 July 2023 and 30 September 2023.
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Estonia Main corporate income tax rate: On 19 June 2023, the Estonian Parliament approved Income Tax Act and Defense Service Act Amendment Act 148 SE which increase the corporate income tax rates by 2 percentage points to reach 22% from 20%.
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France CbC reporting requirement-General rule: On 21 June 2023, France officially released Ordinance No. 2023-483, which mandates the public disclosure of CbC (Country-by-Country) reporting information. The provisions outlined in the Ordinance are applicable to financial years commencing on or after 22 June 2024.
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Germany Scope of transfer pricing rules: On 6 June 2023, the German Federal Ministry of Finance (BMF) has published updated transfer pricing administrative guidelines. The updated guidelines provide general explanations regarding the principles of income correction, the competitive relationship with other correction regulations, and the definitions of related persons and business relationships.
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India Simplified arm’s length range: On 26 June 2023, the Indian Central Board of Direct Taxes (CBDT) has issued Notification No. 46/2023, setting arm’s-length pricing variation limits for the 2023-24 assessment year. The limits are 1 percent for wholesale trading and 3 percent for other cases.
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Ireland CbC reporting requirement-General rule: On 22 June 2023, the Irish Minister for Enterprise, Trade and Employment signed the European Union Regulations 2023 regarding the implementation of public country-by-country reporting in line with Directive (EU) 2021/2101. The Regulation came into effect on 22 June 2023.
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Kenya Transfer pricing information return: On 5 June 2023, the Kenya Revenue Authority (KRA) has issued a public notice regarding the declaration of related party transactions. Accordingly, all taxpayers with related party transactions are required to answer, “Yes”, to the question, under the basic information sheet of the Income Tax Company, on whether they have related parties outside Kenya or control activities.
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Lithuania CbC reporting requirement-General rule: On 15 June 2023, Lithuania has published a law which transposed the EU public Country-by-Country (CbC) Reporting Directive into domestic law. The directive requires multinational groups operating in the EU and that exceed yearly turnover threshold of €750 million to publish certain information on their tax affairs.
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Luxembourg Special rules for hybrid instruments or entities: On 9 June 2023, the Luxembourg Tax Authority published Circular L.I.R. n° 168quater providing guidance on reverse hybrid mismatch regulations including the tax classification of hybrid entities in Luxembourg, the computation of taxable income, and the associated tax compliance responsibilities.
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Malaysia APAs: On 29 May 2023, the Malaysian Inland Revenue Board of Revenue (IRBM) published the Income Tax (Advance Pricing Arrangement) Rules 2023 (“APA Rules 2023”) in their gazette.
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Scope of transfer pricing rules: On 29 May 2023, the Malaysian Inland Revenue Board of Revenue (IRBM) officially published Order No P.U. (A) 165 (TP Rules 2023) introducing a new transfer pricing documentation process effective from assessment year 2023 onwards.
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Malta Digital economy transactions-General: On 23 June 2023, the Maltese Commissioner for Revenue (CFR) published a set of guidelines in relation to the reporting obligations of Digital Platform Operators (DAC7). The DAC7 requirements come into effect on 1 January 2023 into Maltese domestic law.
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Nigeria MAP: On 23 May 2023, the Federal Inland Revenue Service (FIRS) of Nigeria has released Information Circular No. 2023/04 which includes new Guidelines on Mutual Agreement Procedure (MAP). The purpose of the guidelines is to provide guidance on how to obtain assistance from the Nigerian Competent Authority (CA) by a taxpayer whose tax case falls within the scope of a tax treaty between Nigeria and another contracting state.
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Panama Transfer pricing information return: On 26 June 2023, the Panamanian tax authority issued Resolution No. 201-5949, that announced an extension of the deadline for calendar year taxpayers to file transfer pricing return (Form 930) for fiscal year (FY) 2022.
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Spain Digital economy transactions-General: On 25 May 2023, an announcement was published in the Spanish Official State Gazette noting that a bill related to implement the EU directive on DAC7 has been enacted to transpose into domestic law.
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UK Scope of transfer pricing rules: On 19 June 2023 the UK government launched a consultation on potential reforms to the UK legislation on transfer pricing, permanent establishments, and diverted profits tax.
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Documentation-Master file/Local file: On 13 June 2023 the UK government published the Tax Information and Impact Notes for government amendments at the report stage of the Spring Finance Bill 2023. The bill includes the requirement for master file and local file documentation applies to businesses with accounting periods commencing on or after 1 April 2023.
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