Australia Documentation: The Australian Tax Office (ATO) has announced that taxpayers with CbCR obligations for the year ending 31 December 2022 will now have until 31 January 2024 to submit their reports. This extension applies to the CbC report, Master and Local files, generally due by 31 December 2023.
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Belgium Digital economy transactions-General: The Ministry of Finance in Belgium has recently released a Frequently Asked Questions (FAQ) addressing the obligations of digital platform operators imposed by DAC7 (Council Directive (EU) 2021/514).
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CbC reporting requirement-General rule: The Belgian Council of Ministers passed the preliminary draft law for transposing the EU public country-by-country (CbC) reporting directive (2021/2101). This obligation will apply to financial years commencing on or after 22 June 2024.
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Brazil Scope of transfer pricing rules: Brazil published Normative Instruction Nº 2,161 (IN 2,161/23) that governs Brazil’s recently established new transfer pricing law. The new legislation explicitly adopts the arm’s length principle into the Brazilian legal framework, aligning it with OECD standards.
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Chile CbC/Master File/Local File-Deadlines: On 4 October 2023, the Chilean federal tax agency published Resolution No.116 outlining revised filing deadlines of different forms for the 2024 tax year including annual transfer pricing report, the country-by-country report, the master file and the local file.
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Cyprus Information exchange-Bilateral: On 5 October 2023, the Cyprus Tax Department issued a notice regarding the anticipated implementation date of the agreement for the exchange of Country-by-Country (CbC) reports with the United States alongside the local filing obligations.
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Egypt Local file-Deadlines: The Egyptian Tax Authority issued Explanatory Instruction No.78 introducing mandatory transfer pricing reporting obligations for related party transactions. Accordingly, the Tax Authority has set deadlines for submitting transfer pricing local files along with the corporate income tax (CIT) return.
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Ireland Digital economy transactions-General: On 23 October 2023, the Irish Revenue issued eBrief No. 231/23, which provides updated guidance for platform operators for the exchange of information on income generated through digital platforms (DAC7).
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Poland Transfer pricing information return: The Ministry of Finance in Poland decided that it planned to extend the deadline for submitting transfer pricing reporting forms (TPR-P and TPR-C) by 3 months, from 30 November 2023 to 29 February 2024.
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Transfer pricing information return: On 17 October 2023, the Polish Ministry of Finance released new electronic templates for transfer pricing reporting on its website. The templates are used for transfer pricing reporting for tax years starting after 31 December 2021.
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Slovenia Restriction on interest deduction: On 17 October 2023, the Slovenian Ministry of Finance (MoF) issued a draft bill to amend the corporate income tax law. The proposed bill amendments introduce the EBITDA rule (EU Anti-Tax Avoidance Directive -ATAD directive), which limits the deductibility of interest expenses.
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CbC reporting requirement-Deadlines: On 10 October 2023, the Slovenian Tax Agency (Financial Administration) declared that country-by-country (CbC) reports for the fiscal year ending on 31 December 2022, submission is a mandatory requirement by 31 December 2023.
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UAE Scope of transfer pricing rules: On 23 October 2023, the Federal Tax Authority (FTA) of the United Arab Emirates (UAE) released the Transfer Pricing Guide. This guide is designed to provide general guidance on the Transfer Pricing regime in the UAE with a view to making the provisions of the Transfer Pricing regulations as understandable as possible to readers.
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Uganda Digital economy transactions-General: On 20 October 2023, the Uganda Revenue Authority (URA) released a public notice on the implementation of digital service tax (DST). Resident taxpayers and the general public are informed that they are required to withhold tax on payments made to non-resident suppliers of digital services who are not registered with URA under the electronic services taxation regime.
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US Information exchange-Bilateral: The Internal Revenue Service (IRS) of the United States has released the competent authority arrangement concerning exchanging Country-by-Country (CbC) Reports with Israel. This exchange should be completed by 16 December 2023.
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