Azerbaijan Information exchange-Bilateral: On 26 October 2022, the President of the Republic of Azerbaijan published a law ratifying the Inclusive Framework on Base Erosion and Profit Shifting (BEPS), which was approved by the President on 11 October 2022.
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Belgium Penalties for documentation failure: The Belgian tax authorities have sent out the first penalty notifications for noncompliance to submit transfer pricing (TP) forms. The administrative penalty for the first infraction without the intention of tax evasion is set at nil. From the second infraction, the penalties for noncompliance with the TP documentation requirements range from EUR 1,250 to EUR 25,000.
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Colombia Digital economy transactions-General: On 6 October 2022, the Colombian Congress approved Tax Reform Bill in the first debate. The Tax Reform Bill introduces digital service tax applicable to specific services provided by non-residents to Colombian users.
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Cyprus Information exchange-Bilateral: On 13 October 2022, the Cyprus tax authority informed all legal entries and their representatives that the bilateral Competent Authority Arrangement (CAA) for the exchange of Country-by-Country (CbC Reports) between Cyprus and the United States of America which is currently under negotiation, is expected to be effective for Reporting Fiscal Years starting on or after 1 January 2022.
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Hong Kong Filing deadlines: On 19 October 2022, the Hong Kong Inland Revenue Department (IRD) issued a Circular Letter extending the lodgement of 2021/22 tax returns to 30 November 2022.
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Ireland OECD Guidelines: On 20 Oct 2022, Ireland’s Minister for Finance Paschal Donohoe published the Finance Bill 2022 as part of the Irish budget. The Bill contains the update definition of transfer pricing guidelines to reference the OECD’s most recent guidelines published in January 2022.
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Israel Documentation-Requirement: On 22 September 2022, the Israeli Official Gazette published the Income Tax Regulations 2022 including the introduction of the three-tiered transfer pricing documentation requirements of BEPS Action 13.
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Mexico Compliance with BEPS standards: On 12 October 2022, the Mexican Senate approved the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI will generally enter into force for a particular covered agreement and is expected to be applicable from 1 January 2024.
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Mongolia Compliance with BEPS standards: On 6 October 2022, Mongolia signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, at a signing ceremony held in Paris at the 14th meeting of the Inclusive Framework on BEPS.
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Romania CbC reporting requirement-General rule: On 7 September 2022, the Romanian Official Gazette published the regulations to implement the EU directive on CbC report for public disclosure. The Directive requires qualifying multinational companies operating business in the EU to publicly disclose certain information on a country-by-country basis.
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South Africa Related party definition: On 14 October 2022, the South African Revenue Service (SARS) published a draft interpretation note on the definition of “associated enterprise” for public comment which is due on 13 January 2023. This draft note provides guidance on the interpretation and application of the definition of “associated enterprise” in section 31(1) of the Income Tax Act (ITA).
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Compliance with BEPS standards: On 30 September 2022, South Africa deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI will come into effect for South Africa on 1 January 2023.
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Sweden CbC reporting requirement-General rule: On 26 October 2022, the Swedish Tax Agency clarified the guideline for the country-by-country (CbC) reporting followed by the OECD. The guideline includes what additional information must be provided in a country-by-country report if the subsidiaries have longer or shorter financial years than the parent company.
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UK Main corporate income tax rate: On 14 October 2022, the UK government announced that Corporation Tax will increase to 25% (currently 19%) from April 2023 as already legislated for, raising around £18 billion a year and acting as a down payment on its full Medium-Term Fiscal Plan.
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