Armenia Compliance with BEPS standards: On 25 September 2023, Armenia deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI).
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Austria Scope of transfer pricing rules: On 12 September 2023, the Austrian Ministry of Finance published an updated guidance on the explanation and application of the rules of DAC6 in Austria. The updated guidance provides additional clarifications on a number of key areas, including transfer pricing structures.
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Dominican Republic Information exchange-Multilateral: On 5 September 2023, the OECD updated its list of signatories to the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country Reports (CbCR), showing that the Dominican Republic joined the agreement on 6 July 2023.
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Ecuador Scope of transfer pricing rules: Ecuador Internal Revenue Service (SRI) has issued Resolution No. NAC-DGERCGC23-00000025, which modifies the transfer pricing rules. Taxpayers who have conducted transactions with related parties totaling more than US$3 million in a single fiscal year must submit a report on these transactions.
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Greece Digital economy transactions-General: On 7 September 2023, Greece published Law 5047/2023 in the Official Gazette, which transposes EU Council Directive No. 2021/514 (DAC7) into Greece law to implement new rules on the exchange of information on income generated through digital platforms.
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Kenya Scope of transfer pricing rules: On 4 September 2023, the Kenya Revenue Authority (KRA) published draft income tax (Transfer Pricing) rules 2023 for public comment. Comments on the draft Income Tax (Transfer Pricing) Rules for 2023 will be accepted until 22 September 2023.
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Latvia CbC reporting requirement-General rule: On 27 September 2023, the Latvian government released the “Information on Revenue and Income Tax Disclosure Law” in the Official Gazette. This law outlines the framework for the adoption of public Country-by-Country (CbC) reporting, aligning Latvia with the provisions of Directive (EU) 2021/2101.
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Malta Digital economy transactions-General: The Maltese Commissioner for Revenue (CFR) updated 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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Morocco CbC reporting requirement-General rule: The Moroccan General Directorate of Taxation (DGI) has recently released latest Country-by-Country (CbC) reporting guidance. These requirements apply to multinational enterprise (MNE) groups with annual group revenue of MAD 8.1225 billion in the preceding year.
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New Zealand Digital economy transactions-General: The New Zealand Government introduced the Digital Services Tax (DST) Bill into the Parliament. The DST Bill would come into force on either 1 January 2025, or a later date fixed by Order in Council, up to 1 January 2030.
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North Macedonia Transfer pricing information return: On 25 September 2023, North Macedonia officially published amendments to the Profit Tax Law in Official Gazette No.199. According to the amendments, the transfer pricing (TP) report is not required to submit to the tax authorities by 30 September.
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Papua New Guinea Compliance with BEPS standards: On 31 August 2023, Papua New Guinea deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI). It will enter into force for Papua New Guinea on 1 December 2023 and will be in effect for exchanges as of 1 January 2024.
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Poland Cost-plus method: Poland published formal guidance regarding the application of the cost-plus method to ensure accurate valuation of transactions involving related entities for international tax purposes.
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Local file-General rule: On 4 September 2023, the Polish Official Gazetted a notice which outlines the specific reporting and documentation requirements that pertain to the local files, ensuring that companies are well-informed and compliant.
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Sri Lanka Filing deadlines: On 15 September 2023, the Sri Lanka Inland Revenue Department (IRD) released the income tax return forms for the assessment year (AY) 2022-23.
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UK APA: The HMRC has recently updated its guidance (INTM 422000 et seq) on Advance Pricing Agreements (APAs). The updated guidance provides more comprehensive information, particularly in terms of the formal process and HMRC’s expected timeframes.
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Vietnam Compliance with BEPS standards: On 1 September 2023, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Vietnam.
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