Transfer Pricing Brief: December 2023

AustraliaRestriction on interest deduction: On 28 November 2023, the Australian government released the amendments and a supplementary explanatory memorandum to the interest limitation rules within the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and Transparency) Bill 2023.
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Simplified interest rates: On 8 November 2023, the Australian Taxation Office (ATO) released an updated version of practice compliance guideline on simplified transfer pricing record-keeping options (PCG 2017/2). The updates outline the safe harbor interest rate for the 2023–2024 income year regarding low-level related party inbound and outbound loans.
See the story in RegfollowerAzerbaijanCompliance with BEPS standards: Azerbaijan signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). Azerbaijan has become the 102nd jurisdiction to join the BEPS Convention, which now covers over 1900 bilateral tax treaties.
See the story in RegfollowerCanada Digital economy transactions-General: The Deputy Prime Minister and Minister of Finance, tabled the Notice of Ways and Means Motion to introduce the Fall Economic Statement Implementation Act, 2023. The measures include legislation to implement a 3% digital services tax (DST).
See the story in RegfollowerCzech RepublicMain corporate income tax rate: The Parliament of the Czech Republic approved the Act on the Consolidation of Public Budgets, which includes a proposal to increase the corporate income tax rate from 19% to 21%, effective from 1 January 2024.
See the story in RegfollowerFranceScope of transfer pricing rules: The French tax authority published an updated transfer pricing guide for small and medium-sized enterprises (SMEs). The guide covers a wide range of topics, including the concept of transfer pricing, the arm’s length principle, and compliance with the arm’s length principle.
See the story in RegfollowerGreeceCbC reporting requirement-General rule: On 14 November 2023, Greece published Law No. 5066/2023 in the Official Gazette implementing public Country-by-Country (CbC) reporting in compliance with Directive (EU) 2021/2101.
See the story in RegfollowerHungaryInformation exchange-Bilateral:  Hungary formally approved signing a new Country-by-Country (CbC) exchange agreement with the United States. This follows the previous CbC exchange agreement in 2018, which Hungary and the United States signed but was terminated on 8 January 2023.
See the story in RegfollowerItalyDigital economy transactions-General: The Italian Revenue Agency has declared the release of the Provision of 20 November 2023, outlining the execution of updated reporting and information exchange of information requirements pertaining to income generated by sellers utilizing digital platforms (DAC7).
See the story in RegfollowerKuwaitMain corporate income tax rate: According to a recent report, the Kuwaiti government is planning to broaden the scope of corporate income tax to include all entities in Kuwait at a rate of 15%, except for small enterprises.
See the story in RegfollowerPolandTransfer pricing information return: The Polish Ministry of Finance issued a regulation extending the deadline for the submission of transfer pricing information forms (TPR-P and TPR-C forms) for individual (personal) and corporate income taxes until 31 January 2024.
See the story in RegfollowerRussiaInformation exchange-Multilateral: The Russian Federal Tax Service (FTS) released a list of jurisdictions that have repeatedly failed to exchange Country-by-Country (CbC) reports electronically with Russia.
See the story in RegfollowerSingaporeInformation exchange-Multilateral: On 6 November 2023, the Singaporean Official Gazette issued Order No. S 714 confirming the effective dates for the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country Reports (CbC) with Aruba, Barbados, the Faroe Islands, and Thailand.
See the story in RegfollowerSouth AfricaAudits-Burden of proof: On 1 November 2023, the South African Revenue Service (SARS) issued an updated guide on taxation. Pursuant to the guideline, from a compliance perspective, the burden of proof is on the taxpayer to show that the transaction, operation, scheme, agreement, or understanding complied with the arm’s length principle.
See the story in RegfollowerTaiwanCbC/Master file reporting-Deadlines: On 10 November 2023, Taiwan’s Ministry of Finance (MOF) issued a press release as a reminder to the taxpayers to submit master file and country-by-country (CbC) report.
See the story in Regfollower UKCorporate residence: The United Kingdom (UK) HRMC has issued guidance on the transfer pricing records requirements for permanent establishments (PEs) in accordance with the amendments made by Finance (No. 2) Act 2023.
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