Australia Audit risk assessment: The Australian National Audit Office (ANAO) is conducting a performance audit to evaluate the efficiency of the Australian Taxation Office’s (ATO) transfer pricing (TP) management concerning loans between related parties.
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Canada Filing deadlines: On 16 August 2023, the Canada Revenue Agency (CRA) announced that starting from 1 January 2024, businesses filing six or more information returns (slips and summaries) must file electronically to avoid penalties.
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India Safe harbour-Rule: On 9 August 2023, the Central Board of Direct Taxes (CBDT) issued a Notification No. 58/2023, to extend the applicability of the transfer pricing safe harbor rules. The extension applies for the financial year 2022-23 and 2023-24 assessment years.
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Israel MAP-APA: On 17 August 2023, the Israel Tax Authority (ITA) released Tax Circular No. 1/2023, which provides guidance for mutual agreement procedure (MAP), and bilateral advance pricing agreement (APA) requests.
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Luxembourg CbC reporting requirement-General rule: On 22 August 2023, Luxembourg published Law of 15 August 2023 in the Official Gazette implementing public Country-by-Country (CbC) reporting in compliance with Directive (EU) 2021/2101.
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Netherlands CbC reporting requirement-General rule: On 6 July 2023, the Dutch House of Representatives passed legislation aimed at implementing the Public Country-by-Country (CbC) Reporting Directive. If the Senate approves the bill, it is expected that the public disclosure rules will come into effect for financial years commencing on or after 22 June 2024.
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Paraguay Documentation-Requirement: On 20 July 2023, the tax authority of Paraguay (SET) issued General Resolution No. 134 of 18 July 2023, that introduces an exceptional mechanism for the submission of the technical transfer pricing study (Estudio Técnico de Precios de Transferencia or ETPT) and supporting working papers used in performing the analysis.
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Portugal CbC reporting requirement-General rule: On 23 August 2023, the Portuguese government published Decree-Law No. 73/2023 in the Official Gazette, which establishes the requirements for public country-by-country (CbC) reporting by multinational enterprises (MNEs). Decree-Law No. 73/2023 took effect on 24 August 2023 and is applicable to fiscal periods commencing on or after 22 June 2024.
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South Africa APAs-General rules: On 31 July 2023, the National Treasury of South Africa released a draft legislation which includes a proposal implementing advance pricing agreement (APA) program. The proposed legislation sets out the anticipated process, fees, and requirements of APA program.
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South Korea Local File-Master File-Deadline: On 27 July 2023, South Korea’s Ministry of Economy and Finance (MOEF) announced the tax reform proposal for 2023. The proposal reduces the deadline for submitting the Local file and Master file to six months, and additionally, large companies submitting a Local file would also be obliged to submit the Statement of International Transaction.
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UK Scope of transfer pricing rules: The United Kingdom (UK) has published the Transfer Pricing Records Regulations 2023, which updated transfer pricing documentation requirements by introducing Local file and Master file requirements. The Act, which received royal assent in July, brings the UK’s transfer pricing regulations more in line with the OECD guidelines, particularly those developed under BEPS Action 13.
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Digital economy transactions-General: On 20 July 2023, the United Kingdom’s HMRC issued a policy paper outlining a comprehensive plan to establish reporting regulations for digital platform operators operating in the United Kingdom (UK).
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Ukraine CbC reporting requirement-General rule: On 17 August 2023, Ukraine announced that the development of software for the State Tax Service of Ukraine has been completed, which will ensure the international automatic exchange of information under the Common Reporting Standard (CRS) and the Country-by-Country Reporting (CbCR) standard with more than 100 foreign tax administrations.
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