| Bolivia | Filing deadlines: On 28 April 2023, the Bolivian National Tax Service published a Resolution No. 102300000014 extending the corporate income tax (IUE) reporting deadline for the tax year ending 31 December 2022 to 31 May 2023. See the story in Regfollower |
| Brazil | Scope of transfer pricing rules: On 10 May 2023, the Brazilian Federal Senate approved legislation addressing the new transfer pricing which was published on 29 December 2022. This approval is one of the last steps to implement a transfer pricing system in Brazil according to the guidelines set by the OECD. See the story in Regfollower |
| Germany | CbC reporting requirement-General rule: On 11 May 2023, the lower house of the parliament (Bundestag) approves a bill to implement EU Directive, requiring publicly disclose CbC report for qualifying Multinational Enterprises (MNEs) operating in the EU. See the story in Regfollower |
| Kenya | Related party definition: On 28 April 2023, the Cabinet Secretary of the Kenya Ministry of Finance submitted the Finance Bill 2023 (the Bill) to Parliament. The bill proposes to introduce the definition of a related party, where one person participates directly or indirectly in the management, control or capital of another person’s business. CbC reporting requirement-Deadlines: The bill has imposed an obligation on a constituent entity (CE) of a Kenya-based multinational to file a CbC report, outlining some conditions under which a CE must file a CbC report in Kenya. See the story in Regfollower |
| Luxembourg | Digital economy transactions-General: On 19 May 2023, Luxembourg published law no 8029 in the Official Gazette to implement new rules on the exchange of information on income generated through digital platforms (DAC7). The law took into effect starting from 1 January 2023. See the story in Regfollower |
| Malaysia | Documentation-Requirement: 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. Documentation-Timing and deadlines: The Inland Revenue Board (IRB) currently accepts documentation as ‘contemporaneous’ if it is submitted within 14 days of a written request. This additional stipulation strengthens the need for taxpayers to prepare contemporaneous documentation when filing their tax returns. Priority of methods: The TP Rules 2023 introduce the best method approach from the OECD Guidelines as a replacement for the hierarchy of methods. See the story in Regfollower APAs-Application procedure: 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. Taxpayers now have an extended period of 6 months, instead of the previous 2 months, to submit the formal application after receiving a positive notification from the DG. See the story in Regfollower |
| Portugal | Filing deadlines: On 22 May 2023, the Portuguese Tax and Customs Authority (AT) has granted an Order No.148/2023-XXIII which provides an extension of submitting corporate income tax returns deadline to 6 June 2023 which was due on 31 May 2023. See the story in Regfollower |
| Spain | Restriction on interest deduction: On 25 May 2023, Spain published Law 13/2023 in the Official Gazette, which introduces new interest deduction limitation rules in line with the EU Anti-Tax Avoidance Directive (ATAD). The new rules, effective from 1 January 2024, stipulate that the deduction of net interest expense is capped at 30% of the year’s EBITDA, with disregarded income, expenses or rent being specifically excluded in the tax base. See the story in Regfollower |
| Sri Lanka | Adjustments-MAP: On 8 May 2023, the Sri Lanka Inland Revenue Department (IRD) has published Mutual Agreement Procedure (MAP) guidelines explaining the procedure for submitting a MAP request to Sri Lanka’s competent authority (CA) in specific circumstances. See the story in Regfollower |
| UAE | Documentation-Requirement: On 11 May 2023, the UAE Ministry of Finance (MoF) issued Ministerial Decision No. 97 of 2023 on the requirements for maintaining transfer pricing (TP) documentation. The decision specifies instances where taxpayers must maintain transfer pricing documentation, specifically a master file and a local file. See the story in Regfollower |
| US | APAs-Application procedure: On 25 April 2023, the Internal Revenue Service (IRS) published a memorandum providing guidance to employees of the Treaty and Transfer Pricing Operations (TTPO) practice area in the Large Business and International Division (LB&I) with respect to requests from taxpayers for an APA with the IRS. See the story in Regfollower |
| Vietnam | Compliance with BEPS standards: On 23 May 2023, Vietnam ratified the Multilateral Convention to implement tax treaty-related measures to prevent BEPS (MLI). With this ratification, Vietnam becomes the 81st jurisdiction to join the convention, which will come into effect in Vietnam on 1 September 2023. See the story in Regfollower |
