Algeria Filing deadlines: The Algerian Directorate General of Taxes (DGI) has extended the deadline for filing corporate tax returns to 31 May 2023 for the tax year 2022.
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Brazil Scope of transfer pricing rules: The Brazilian Lower House of Congress adopted Measure No. 1,152 to overhaul its transfer pricing system that was introduced on 29 December 2022.
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Chile MAP: On 19 April 2023, the Chilean tax authority published a Circular clarifying time limits for MAP requests. The circular clarifies that the three-year time limit commences from the first business day following the initial notification of an action that results in taxation not in line with the applicable tax treaty’s provisions.
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Hong Kong Filing deadlines: On 14 April 2023, the Inland Revenue Department (IRD) of Hong Kong issued a Circular Letter providing an extension of due date for certain taxpayers. Despite the extension, tax representatives are encouraged to file as many returns as possible well before the extended due date.
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Filing deadlines: On 3 April 2023, the Inland Revenue Department issued profits tax returns and property tax returns for the year of assessment 2022-23. Taxpayers and employers are generally required to file their returns within one month from the date of issue of the relevant returns.
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Luxembourg Scope of transfer pricing rules: On 28 March 2023, Luxembourg government submitted a bill to the Parliament proposing changes in advance pricing arrangement (APA), mutual agreement procedure (MAP), compliance with transfer pricing documentation requirements, and general tax procedures.
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Norway Restriction on interest deduction: The Norwegian Ministry of Finance launched a public consultation providing a proposal to change the interest limitation rules, which generally limit the deduction of interest expenses for related parties that exceed 25% of EBITDA when annual net interest expenses exceed NOK 5 million.
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Poland Applicable methods-Resale price method: The Polish Ministry of Finance published guidance clarifying the application of the resale price method to determine the arm’s length value of transactions between related parties.
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Saudi Arabia Scope of transfer pricing rules: Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) approved Decision No. 8-2-23 to amend the Transfer Pricing (TP) Bylaws. Starting from 1 January 2024, the TP Bylaws will be applicable to both taxpayers and Zakat payers.
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South Africa Related party definition: On 17 April 2023, the South African Revenue Service (SARS) published an interpretation note 128 providing guidance on the interpretation and application of the definition of “associated enterprise” in Income Tax Act (ITA).
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Turkey Filing deadlines: On 25 April 2023, Turkish Revenue Administration extended the corporate tax return and payment deadline for the accounting period 2022.
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Uganda Digital economy transactions-General: Uganda proposes a 5% digital service tax (DST) under the Income Tax (Amendment) Bill 2023 issued on 30 March 2023. After the final approval, the measure will take effect from 1 July 2023.
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US APAs-General rules: The Internal Revenue Service (IRS) Large Business and International (LB&I) division released a memorandum providing guidance to TTPO personnel with respect to requests from taxpayers for an APA with the IRS. The guidance applies to both APA prefiling memoranda and APA submission requests, including renewals.
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Information exchange-Bilateral: US and Germany signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. CbC Reports are intended to be exchanged with respect to Fiscal Years of MNE Groups commencing on or after January 1, 2021.
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