Transfer Pricing
KPMG TaxNewsFlash reports of transfer pricing developments
News
Germany: Transfer pricing documentation requirements for extraordinary business transactions in 2025
New rules require automatic submission within 30 days of transfer pricing documentation upon notification of an audit
March 28, 2025
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Announcement 2025-13: U.S. APMA program, APA statistics for 2024
26th report describing the experience, structure, and activities of the APMA program
March 27, 2025
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KPMG article: How generative AI can improve transfer pricing processes
Questions and points to consider when using GenAI
March 26, 2025
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Iceland: Transfer pricing adjustment and penalty upheld (Reykjavik District Court decision)
The court upheld the tax authority´s transfer pricing adjustment and 25% penalty surcharge in the country’s first transfer pricing court case.
March 24, 2025
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KPMG article: Effect of digital transformation on transfer pricing
Examples of how digital transformation is creating transfer pricing issues for multinational enterprises
March 18, 2025
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Italy: Ministerial Decree on GloBE information return (GIR) notifications
The actual notification form and further details on the submission will be clarified by the revenue agency.
March 18, 2025
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Bahrain: Updated domestic minimum top-up tax (DMTT) registration manual
Version 1.0 released on March 9, 2025
March 17, 2025
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Turkey: Announcement that Amount B under Pillar One will not be applied
Official announcement on March 7, 2025
March 17, 2025
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Belgium: Recent trends in transfer pricing audits
Overview of recent trends in transfer pricing audits in Belgium
March 14, 2025
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Kazakhstan: Changes to rules for monitoring cross-border transactions; additional deductions for R&D expenses
Changes to rules for monitoring cross-border transactions are effective January 27, 2025
March 13, 2025
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Dominica: Mutual agreement procedure (MAP) guidelines
Guidelines clarify that Dominica does not offer bilateral advance pricing agreements (APAs)
March 12, 2025
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Canada: Late amendment by tax authority in transfer pricing dispute allowed (Tax Court decision)
Amendment made after deadline for competent authority relief under treat had expired
March 11, 2025
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EU: Council reaches political agreement on DAC9
Member states need to implement the directive into national legislation by December 31, 2025.
March 11, 2025
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Cameroon: Guidelines for local country-by-country declarations
Content, format, and procedures for filing local CbC declarations
March 6, 2025
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Indonesia: Implementation of global minimum tax
Enforcement of global anti-base erosion (GloBE) rules from January 1, 2025
March 5, 2025
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Australia: Tax authority statement regarding Federal Court decision that taxpayer entitled to interest deductions with respect to foreign related-party financing
Statement summarizes tax authority’s views on the decision
March 4, 2025
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Serbia: Rulebook on arm’s length interest rates for 2025
Interest rates for all non-finance entities and a single interest rate for banks and finance leasing companies
March 4, 2025
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UAE: FAQs on Pillar Two domestic minimum top-up tax
Ministry of Finance published a list of “frequently asked questions”
March 4, 2025
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Latest tax developments from the United States and from KPMG member firms around the globe
News
Israel: Consultation on draft guidance regarding local R&D centers and IP valuations
Draft guidance on arrangements for which the tax authority may provide certainty
February 27, 2025
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OECD: Report to G20 Finance Ministers and Central Bank Governors, recent developments in international tax cooperation
Recent developments include implementation of BEPS minimum standards and Two-Pillar solution
February 27, 2025
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Slovakia: Proposed amendments to implement exchange of Pillar Two information between EU member states (DAC9)
Minister of Finance announced amendments on January 20, 2025
February 27, 2025
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Denmark: Proposed amendments to Pillar Two law
Comments are due by March 3, 2025.
February 26, 2025
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EU: Public meeting of European Parliament Subcommittee on Tax Matters with European Commissioner responsible for tax
EU will not withdraw from Pillar Two agreement and remains committed to reaching Pillar One agreement
February 26, 2025
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OECD: Consolidated report on Amount B
Incorporates materials on Amount B released from February 2024 until December 2024
February 24, 2025
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Chile: Updated procedures for transfer pricing adjustments; other direct and indirect tax developments
A report summarizing recent direct and indirect tax developments
February 21, 2025
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Poland: List of jurisdictions with qualified status for Pillar Two purposes
List applies for purposes of local implementation of Pillar Two rules
February 20, 2025
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Vietnam: MCAA for exchange of CbC reports signed; amendments to transfer pricing regulations
Report on recent transfer pricing developments in Vietnam
February 20, 2025
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Ukraine: Updates to scope of “controlled transactions” for transfer pricing purposes
Updated list of low-tax jurisdictions, transactions with permanent establishment in Ukraine of Austrian limited partnership
February 19, 2025
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Spain: Public country-by-country reporting obligations
Overview of public CbC reporting obligations in Spain
February 14, 2025
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Kenya: Legislation replacing digital services tax with significant economic presence tax, implementing Pillar Two rules
Legislation also includes withholding tax and VAT changes
February 13, 2025
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Cyprus: Penalty relief for late 2022 tax filings
Tax filings must be submitted by May 31, 2025
February 13, 2025
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Costa Rica: Guidance on obligation of certain taxpayers to submit annual transfer pricing information return
Guidance includes format of return and instructions
February 13, 2025
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Sweden: Government report to Parliament on EU proposal for exchange of Pillar Two information between EU member states (DAC9)
Report regarding changes potentially required for implementation in Sweden
February 13, 2025
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UAE: Legislation implementing Pillar Two global minimum tax rules
Effective for financial years beginning on or after January 1, 2025
February 12, 2025
News
France: Tax measures in Finance Act 2025
Includes direct and indirect tax measures affecting companies
February 11, 2025
News
Italy: List of jurisdictions with transitional qualified status for Pillar Two purposes
List applies for purposes of local implementation of Pillar Two rules
February 7, 2025
News
UK: Amendments to Pillar Two rules in amended Finance Bill 2024-2025
Including incorporation of provisions from OECD June 2024 Administrative Guidance
February 7, 2025
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UK: HMRC transfer pricing and diverted profits tax statistics for FY 2023-2024
Statistics show HMRC continues to be very active on transfer pricing initiatives
February 6, 2025
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UK: Consultation on supplementary draft guidance on Pillar Two global minimum tax rules
Last consultation before guidance manual will be published in late spring 2025
February 6, 2025
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India: Tax measures in budget 2025-2026
Measures related to direct and indirect tax, transfer pricing, and customs duties
February 3, 2025
News
Kazakhstan: Changes to transfer pricing laws included expanded reporting and disclosure requirements
Changes became effective January 10, 2025
February 3, 2025
Highlighted Insights
Global Transfer Pricing Review
Comprehensive information covering more than 100 countries and feedback on more than 200 questions covering local transfer pricing rules and regulations
Read more
News
Germany: Updated list of non-cooperative tax jurisdictions, consultation on draft amendments to Pillar Two rules, changes to transfer pricing rules, other tax developments
Recent tax developments in Germany
January 30, 2025
News
Japan: Updated guidance on income inclusion rule
Income inclusion rule was amended in 2024 tax reform
January 29, 2025
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KPMG report: German case law regarding transfers of functions
Some courts have held in favor of taxpayers arguing their transactions did not result in transfers of functions.
January 28, 2025
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Bahrain: Updated domestic minimum top-up tax registration manual
Updated version of domestic minimum top-up tax registration manual released
January 27, 2025
News
France: Form for Pillar Two reporting requirements, country-by-country notification
Pillar Two reporting requirements added to CbC notification form
January 27, 2025
News
Korea: Transfer of shares subject to capital gains tax at arm’s length fair market value (Tax Tribunal decision)
Tax Tribunal decision
January 27, 2025
News
Australia: Legislation providing details on computation of top-up tax under Pillar Two rules
Rules are effective from January 1, 2024.
January 22, 2025
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Australia: New transfer pricing guidance on inbound related-party funding for property and construction
Guidance highlights concerns and factors that attract tax authority’s attention
January 22, 2025
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Malaysia: Transfer pricing guidelines and audit framework for 2024
Guidelines are effective from year of assessment 2023, and framework is effective from December 24, 2024.
January 22, 2025
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South Africa: Legislation implementing Pillar Two global minimum tax rules enacted
Rules are effective for tax years beginning from January 1, 2024
January 22, 2025
News
White House announcement on OECD “Global Tax Deal”
A memorandum from President Trump’s White House regarding the OECD “Global Tax Deal”
January 21, 2025
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Cyprus: Implementation of Pillar Two global minimum tax rules and public country-by-country reporting
Implementing laws largely align with EU directives
January 21, 2025
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Bahrain: Guide on entities within scope of domestic minimum top-up tax
Further clarification on various aspects including entities that fall within scope of domestic minimum top-up tax
January 21, 2025
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EU: Tax priorities of Polish Presidency of the Council
Include updating list of non-cooperative jurisdictions for tax purposes and work on DAC9
January 21, 2025
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Relationship between arm’s length standard and specific period adjustment rules in section 482 regulations
Legal advice memorandum from the Office of Chief Counsel
January 21, 2025
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Romania: Clarifications on reporting form for public country-by-country disclosures
The Romanian Ministry of Finance issued a press release with regards to the reporting template to be used for public country-by-country disclosures.
January 21, 2025
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Thailand: Law implementing Pillar Two global minimum tax rules published
Rules became effective January 1, 2025
January 21, 2025
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Slovenia: Implementation of public country-by-country reporting
New provisions apply to financial years beginning on or after June 22, 2024.
January 21, 2025
News
KPMG report: Inclusive Framework guidance on application of GloBE rules
Including guidance relating to GloBE information return
January 17, 2025
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KPMG report: Inclusive Framework Administrative Guidance on limitation of the use of deferred tax assets under transitional rules (Article 9.1)
Focuses on the guidance on deferred tax assets under Article 9.1
January 17, 2025
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OECD: Inclusive Framework on BEPS releases updates to global minimum tax administration
Additional administrative guidance under the Pillar Two rules
January 15, 2025
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Spain: Law implementing Pillar Two global minimum tax approved
Law also includes amendments relating to corporate income tax, individual (personal) income tax, VAT, tax on financial entities, and excise duties.
January 15, 2025
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UAE: Guidance on tax groups, including transfer pricing rules applicable to groups
New guidance effective January 1, 2025
January 15, 2025
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KPMG article: Tax issues raised by development of valuable digital IP and data assets
Including transfer pricing issues
January 15, 2025
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Statement by co-chairs of Inclusive Framework on BEPS indicates still no consensus on Pillar One
The statement indicates that the co-chairs intend to continue working to achieve a consensus on the Amount B Framework and so the overall Pillar One package.
January 13, 2025
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China: Report on advance pricing agreement (APA) program
Total of 296 APAs signed from 2025 to 2023, with 36 signed in 2023
January 13, 2025
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Denmark: Taxpayer prepared adequate transfer pricing documentation and related party payments were arm’s length (Supreme Court decision)
Court rejected tax authority’s argument that taxpayer’s transfer pricing documentation could be disregarded and discretionary income adjustment imposed
January 9, 2025
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Ireland: Application of Pillar Two global minimum tax rules to fund vehicles and securitization entities
Reports discussing key considerations for fund vehicles and Irish securitization entities
January 9, 2025
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North Macedonia: Parliament adopts law implementing Pillar Two global minimum tax rules
Law aligns with EU minimum tax directive
January 9, 2025
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India: Report on advance pricing agreement (APA) program
Total of 125 APAs signed in FY 2023-2024
January 8, 2025
News
Oman: Legislation implementing Pillar Two global minimum tax rules
New legislation introduces domestic minimum top-up tax (DMTT) for multinational groups
January 8, 2025
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Kuwait: Legislation implementing Pillar Two global minimum tax rules
New legislation introduces domestic minimum top-up tax (DMTT) for multinational groups
January 8, 2025
News
Sri Lanka: New advance pricing agreement (APA) guide
Guide allows for unilateral, bilateral, and multilateral APAs
January 8, 2025
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Barbados: Extension of deadline for country-by-country reports
Extension for MNE groups with fiscal year-ends between October 1 and December 31, 2023, until January 31, 2025
January 6, 2025
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El Salvador: Program to enhance audit and investigation capabilities for tax crimes and transfer pricing
Program aimed at reducing tax evasion and increasing tax collection
January 6, 2025
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KPMG article: Commensurate with income standard in transfer pricing
Evolution of the commensurate with income (CWI) standard, its current and prospective application, and its practical implications for taxpayers
January 6, 2025
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KPMG article: Examination of UK’s “one-way street” transfer pricing rule
A strict “one-way street” approach may be unnecessary in light of major developments in the international tax landscape and the UK.
January 6, 2025
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Portugal: Relatedness determined on transaction date; improper rejection of transfer pricing method (Supreme Administrative Court decisions)
The Supreme Administrative Court issued two recent decisions relating to application of transfer pricing rules.
December 30, 2024
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Hong Kong: Draft legislation implementing Pillar Two global minimum tax rules
Draft legislation will be presented to the Legislative Council on January 8, 2025.
December 27, 2024
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Ireland: Tax measures in Finance Bill 2024 include Pillar One Amount B rules, amendments to Pillar Two rules
Tax measures effective from November 12, 2024
December 27, 2024
News
Japan: Outline of 2025 tax reform proposals, including new Pillar Two rules
Proposals include introduction of undertaxed profits rule (UTPR) and qualified domestic minimum top-up tax (QDMTT)
December 27, 2024
News
Cambodia: New transfer pricing regulations
New regulations include rules relating to required transfer pricing documentation
December 20, 2024
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Luxembourg: Overview of tax measures for 2025, including amended Pillar Two law
Comprehensive overview of the key tax measures for 2025
December 20, 2024
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KPMG report: Proposed adoption of Amount B in the United States
Notice 2025-4 would allow the U.S. application of Amount B—an OECD-initiative to simplify transfer pricing for baseline marketing and distribution activities.
December 19, 2024
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OECD: Fact sheets and pricing tool for implementation of Amount B simplified approach
Fact sheets provide overview of Amount B mechanics, Pricing Automation Tool computes Amount B return for in-scope tested parties
December 19, 2024
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Hungary: Changes to autumn tax package, including Pillar Two rules, agreed by Parliament
Approved version narrows the scope of data that companies subject to global minimum tax are required to report by the end of the year.
December 19, 2024
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Notice 2025-4: Application of Pillar One Amount B simplified and streamlined approach
Treasury and IRS announce intention to issue proposed regulations applicable to tax years beginning on or after January 1, 2025.
December 18, 2024
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Australia: List of specified jurisdictions for public country-by-country reporting
List includes 40 specified jurisdictions
December 18, 2024
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Netherlands: Upper house passes entire 2025 Tax Plan package, including amendments to Pillar Two rules
In total, 11 tax bills and an amending act were passed.
December 18, 2024
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Georgia: Amended transfer pricing regulations
Regulations amended to refer to latest OECD Transfer Pricing Guidelines
December 17, 2024
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Australia: Changes to country-by-country reporting exemption process
Changes effective for all exemption requests submitted after January 1, 2025
December 16, 2024
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Bahrain: Pillar Two global minimum tax implementing regulations
The regulations prescribe detailed rules, conditions, and procedures for implementation and enforcement of the Pillar Two global minimum tax.
December 16, 2024
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Gibraltar: Draft legislation implementing Pillar Two global minimum tax rules
Top-up tax would apply for financial years starting on or after December 31, 2023
December 16, 2024
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Australia: Updated guidance on public country-by-country reporting
Updates regarding public country-by-country reporting parent registration
December 12, 2024
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France: Guidance on Pillar Two global minimum tax filing and notification obligations
Decree specifying Pillar Two filing and notification obligations published on December 5, 2024.
December 12, 2024
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EU: Final public country-by-country reporting forms published
Implementing regulation effective for financial years starting on or after January 1, 2025
December 12, 2024
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EU: ECOFIN report on various tax initiatives
Report includes updates on Unshell Directive, Transfer Pricing Directive, BEFIT Directive, and DAC9 proposals
December 12, 2024
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Malaysia: Guidance on Pillar Two global minimum tax
The guidance covers scope, filing obligations, transitional penalty relief, and safe harbors.
December 12, 2024
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Australia: Pillar Two minimum tax, public CbC reporting, and foreign residents’ capital gains withholding bills receive Royal Assent
Legislation received Royal Assent on December 10, 2024.
December 11, 2024
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KPMG article: OECD advance pricing agreement statistics for 2023
The statistics offer insights to businesses managing their transfer pricing risks.
December 10, 2024
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Nigeria: Guidelines on advance pricing agreements
Guidelines on the procedures and conditions for advance pricing agreements in Nigeria
December 9, 2024
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India: Transfer pricing rules applicable to transactions between foreign company and its Indian branch (Tribunal decision)
Rules must be applied because foreign company taxable in India only on the income of its Indian branch
December 6, 2024
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Lithuania: New country-by-country reporting notification requirements
New rules require that notifications be completed, submitted, and corrected electronically
December 6, 2024
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Netherlands: Guidance on how Pillar One Amount B will affect domestic taxpayers
Guidance becomes effective January 1, 2025
December 5, 2024
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OECD: Updated International Compliance Assurance Programme (ICAP) FAQs (December 2024)
Revised FAQs reflect favorable developments in the ICAP program
December 5, 2024
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KPMG report: Update on future of BEPS guidance from OECD
Noel Maher, Tax Policy Adviser from the OECD, discussed ongoing work at the OECD at KPMG-sponsored conference
December 4, 2024
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KPMG article: Managing Italian transfer pricing audits
Complex transfer pricing examinations in Italy can lead to complications and risks for multinational enterprises.
December 4, 2024
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Spain: Legislation implementing Pillar Two global minimum tax passed by lower house of Parliament
The legislation also includes amendments relating to corporate income tax, individual (personal) income tax, VAT, tax on financial entities, and excise duties.
December 4, 2024
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Germany: Changes to transfer pricing documentation requirements effective January 1, 2025
Changes introduced under Fourth Bureaucracy Relief Act include shorter response times and new “transaction matrix”
December 3, 2024
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Australia: Parliament passes legislation implementing public country-by-country reporting
The legislation now awaits Royal Assent.
December 2, 2024
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Australia: Parliament passes Pillar Two minimum tax bills
The legislation now awaits Royal Assent.
December 2, 2024
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Australia: Guidance on international transactions that attract scrutiny
Focus on related-party financing, transfer pricing, and thin capitalization rules
December 2, 2024
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Moldova: Guidance on various transfer pricing, VAT, and income tax issues
Guidance on transfer pricing includes introduction of advance pricing agreements (APAs) from January 1, 2025
December 2, 2024
Tax Services
News
Australia: Legislation implementing Pillar Two global minimum tax rules passes Senate
Two bills will return to the House of Representatives, while the other awaits Royal Assent
November 27, 2024
News
Hungary: Draft declaration form for taxpayers subject to global minimum tax
Form includes some changes from autumn tax package proposal
November 27, 2024
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Hungary: Amended autumn tax package submitted to Parliament
Tax changes expected to come into effect in Hungary
November 22, 2024
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Poland: Legislation implementing global minimum tax effective January 1, 2025
The new regulations target groups with annual revenues of €750 million or more.
November 21, 2024
News
UK: Amendments to Pillar Two rules in Finance Bill 2024-2025
Seeks to incorporate the undertaxed profits rule (UTPR) into UK domestic law
November 21, 2024
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KPMG article: United States-Chile treaty builds tax certainty for MNEs with MAPs and APAs
Mutual agreement procedures and advance pricing agreements to mitigate double taxation
November 21, 2024
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Barbados: Filing extension for country-by-country notifications; other tax developments
Recent developments also concern economic substance exchange jurisdictions and land tax adjustments
November 20, 2024
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Singapore: Bills to implement global minimum tax; list of jurisdictions for exchange of CbC reports; applying for certificates of residence
Parliament passed bills to implement the multinational enterprise top-up tax and the domestic top-up tax
November 20, 2024
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South Africa: Updated legislation implementing Pillar Two global minimum tax rules submitted to Parliament
The government submitted legislation to implement the OECD’s Pillar Two GloBE model rules.
November 20, 2024
News
EU: Updated public country-by-country reporting forms published
Implementing regulation effective for financial years starting on or after January 1, 2025
November 19, 2024
News
OECD: Mutual agreement procedure (MAP) and advance pricing agreement (APA) statistics for 2023
Decrease in global MAP inventories with more cases resolved and an increase in global APA inventories
November 18, 2024
News
Australia: ATO extends filing deadline for country-by-country reporting entities
The ATO has granted a filing deferral through January 31, 2025.
November 15, 2024
News
Poland: Legislation implementing Pillar Two global minimum tax rules passed by upper house of Parliament
The legislation is expected to become effective January 1, 2025.
November 13, 2024
News
Slovakia: Transfer pricing for manufacturing companies (court decisions)
Insights into how a taxpayer's functions and risks within a group are evaluated
November 13, 2024
News
Armenia: Agreement on automatic exchange of country-by-country reports
Enables the automatic exchange of key financial information from multinational enterprises
November 12, 2024
News
Bahamas: Proposed Pillar Two legislation
Minimum effective tax rate of 15% for MNE groups with global revenues exceeding €750 million
November 12, 2024
News
Montenegro: Multilateral agreement on exchange of country-by-country reports
MNE groups with consolidated revenues exceeding €750 million must file reports within 12 months after fiscal year-end
November 12, 2024
News
UAE: Tax guide on corporate tax returns includes transfer pricing thresholds and procedures
A tax guide on corporate tax returns detailing the contents and procedures for filing.
November 12, 2024
News
Luxembourg: Revised draft law amending Pillar Two law
Revised draft law introduces additional amendments to initial amending draft law published in June 2024
November 8, 2024
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Hungary: Reporting obligation of taxpayers subject to global minimum tax
Taxpayers subject to global minimum tax must fulfill reporting obligation by December 31, 2024.
November 7, 2024
News
Israel: Proposed "Green Track" for R&D centers
“Green Track” would provide certainty on transfer pricing treatment of local R&D centers providing services to foreign MNEs
November 7, 2024
News
Chile: Amendments to transfer pricing rules
Advance pricing agreements (APAs), definitions and specifications of concepts, and self-adjustments
November 4, 2024
News
Portugal: Bill implementing Pillar Two passed by Parliament
Parliament passed a bill transposing the EU minimum tax directive into domestic legislation
November 4, 2024
News
Norway: Budget would introduce undertaxed profits rule (UTPR) from 2025
A proposal to introduce an undertaxed profits rule from 2025
November 4, 2024
News
Italy: Guidance on substance based income exclusion (SBIE) provisions under Pillar Two rules
The decree incorporates clarifications provided in the OECD commentary and December 2023 administrative guidance.
November 4, 2024
News
Hong Kong: Outcomes from Pillar Two consultation
Key points contained in the government’s responses
November 4, 2024
News
Netherlands: Letter submitted to Parliament on Pillar Two effect on Dutch tax incentives
Effect expected to be limited
November 4, 2024
News
Poland: Proposed reforms to tax incentives system in light of Pillar Two
Government is considering introduction of cash grant regime in lieu of existing investment zone and R&D tax credit regimes
November 4, 2024
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Germany: Annual Tax Act 2024 passed by lower house of Parliament includes Pillar Two changes, other tax developments
Recent tax developments in Germany
October 31, 2024
News
UK: Pillar Two tax measures in Autumn Budget 2024
Undertaxed profits rule (UTPR) will be included in the Finance Bill 2024-2025
October 31, 2024
News
Cyprus: Extended deadlines for submitting 2022 and 2023 tax returns for taxpayers obligated to submit table of summarized information
New deadlines are February 28, 2025, and November 30, 2025, respectively
October 30, 2024
News
EU: Proposal for exchange of Pillar Two global minimum tax information between EU member states (DAC9)
DAC9 proposal would transpose the global anti-base erosion (GloBE) information return (GIR) into EU law.
October 30, 2024
News
Germany: Registering Pillar Two minimum tax group leader
Ministry of Finance has published a notification form for registering the minimum tax group leader.
October 30, 2024
News
Hungary: Autumn tax package includes proposed Pillar Two amendments
Tax changes expected to come into effect in Hungary
October 29, 2024
News
Malta: 2025 budget includes update on Pillar Two implementation
Highlights of Budget 2025
October 29, 2024
News
New Zealand: Summary of implementation of Pillar Two GloBE rules
Rules effective for fiscal years starting on or after January 1, 2025
October 29, 2024
News
Isle of Man: Update on implementation of Pillar Two global minimum tax
The new rules would take effect for accounting periods beginning on or after January 1, 2025.
October 28, 2024
News
Austria: Appointment of alternative Pillar Two taxpayer due by December 31, 2024
Proof of appointment must also be uploaded in FinanzOnline
October 24, 2024
News
OECD: Developments in international tax reform—digitalization of the economy and BEPS minimum standards
Recent developments in international tax reform since July 2024
October 24, 2024
News
KPMG article: Potential effects of artificial intelligence on transfer pricing
An article that discusses the potential effects of artificial intelligence on transfer pricing and transfer pricing audits
October 22, 2024
News
Belgium: Public consultation on draft tax return under Pillar Two rules
Comments are due November 8, 2024.
October 21, 2024
News
Bulgaria: Public consultation on proposed amendments to Pillar Two rules
The consultation runs until October 18, 2024.
October 16, 2024
News
Netherlands: 2025 Tax Plan includes proposed amendments to Pillar Two rules
Most of the proposed amendments would have retroactive effect as of December 31, 2023.
October 16, 2024
News
Slovakia: Draft legislation amending Pillar Two rules submitted to Parliament
The proposed amendments would become effective as of December 31, 2024.
October 16, 2024
News
Lithuania: Public consultation on draft legislation fully implementing Pillar Two rules
The proposed Pillar Two rules would closely follow the text of the EU minimum tax directive.
October 16, 2024
News
Italy: Public country-by-country reporting implemented
The new provisions apply to financial years beginning on or after June 22, 2024.
October 16, 2024
News
France: Finance Bill 2025 includes proposed retroactive tax increases for large corporations and individuals, updates to Pillar Two rules
The Finance Bill for 2025 was published on October 10, 2024.
October 15, 2024
News
Ireland: Tax measures in Finance Bill 2024, including Pillar One Amount B rules, amendments to Pillar Two rules
Includes tax measures announced in 2025 budget
October 11, 2024
News
UK: Initial analysis of OECD’s model competent authority agreement on application of Amount B under Pillar One
MCAA can be used to apply Amount B when there is a tax treaty in place between two jurisdictions
October 10, 2024
News
Netherlands: Interest deduction limitation anti-profit shifting rule permissible under EU law (CJEU judgment)
Rule is justified as a means of combating tax fraud and evasion
October 8, 2024
News
Brazil: Implementation of Pillar Two rules establishes qualified domestic minimum top-up tax
Officially aligns Brazil with countries that have adopted the OECD's global anti-base erosion (GloBE) rules
October 7, 2024
News
New Zealand: Updated compliance focus guide for multinationals reflects BEPS, Pillar Two changes
Guidance for multinationals in self-assessing their international tax and transfer pricing risk profiles
October 7, 2024
News
OECD: Model competent authority agreement on application of Amount B under Pillar One
Intended to assist countries in resolving potential double taxation in connection with application of Amount B when there is a bilateral tax treaty in effect
October 7, 2024
News
Poland: Draft legislation implementing Pillar Two global minimum tax rules submitted to lower house of Parliament
The legislation is expected to become effective January 1, 2025.
October 2, 2024
News
Chile: Tax compliance bill approved by Congress includes income tax, VAT, and transfer pricing measures
The Tax Compliance Bill, which includes a number of tax measures, was approved by Congress.
September 30, 2024
News
KPMG article: Survey on application of control of risk and DEMPE frameworks, focus on Japan
KPMG survey regarding how local tax authorities are approaching the control of risk and development, enhancement, maintenance, protection, and exploitation (DEMPE) frameworks
September 30, 2024
News
KPMG article: Worldwide trends in transfer pricing
Case studies address common transfer pricing issues in several representative jurisdictions
September 30, 2024
News
Cyprus: Additional FAQs on new transfer pricing rules
Aims to clarify certain provisions of the new transfer pricing rules
September 26, 2024
News
UK: Consultation on additional draft guidance on Pillar Two global minimum tax rules
Comments are due by October 23, 2024.
September 26, 2024
News
Korea: Sales volume must be considered in determining comparability of transactions for transfer pricing purposes (Administrative Court decision)
Allegedly comparable transactions relied on by the tax authority were not, in fact, comparable
September 25, 2024
News
KPMG report: U.S. transfer pricing and international tax year-end considerations
A report that includes key year-end transfer pricing and international tax issues.
September 25, 2024
News
Peru: Changes to APA rules and introduction of new valuation methods
Changes to the transfer pricing regime effective January 1, 2025
September 25, 2024
News
KPMG article: Reconsidering maquiladoras in light of recent tax reforms in Mexico
Why businesses may need to reconsider their Maquiladora tax regime structures
September 23, 2024
News
Australia: Increased reporting requirements for Local file
Proposed Local file and Master file XML schema 4.0
September 20, 2024
News
OECD: Jurisdictions sign multilateral convention implementing Pillar Two subject to tax rule
Nine jurisdictions signed the multilateral convention to implement the STTR in bilateral income tax treaties.
September 19, 2024
News
U.S. House Republican leadership, Ways and Means members express opposition to Pillar Two deal in letter to OECD
Sent a letter to the OECD Secretary-General expressing their opposition
September 18, 2024
News
Peru: Import and export of commodities subject to transfer pricing regulations
Companies must submit Informative Affidavit by the day of arrival for imports and the day of shipment for exports.
September 18, 2024
News
OECD: Annual peer review of BEPS Action 13 minimum standard on country-by-country reporting
Key findings from the OECD report
September 17, 2024
News
Albania: Country-by-country reporting legislation implemented
Detailed rules and procedures to be followed by ultimate parent entities and constituent entities of an MNE group
September 16, 2024
News
Italy: Comparable entities must be included in transfer pricing comparability analysis (Supreme Court decision)
A Supreme Court decision concerning whether potentially comparable entities can be excluded from a transfer pricing comparability analysis solely based on their lower profit levels or losses.
September 13, 2024
News
Switzerland: Announcement regarding implementation of income inclusion rule
Effective January 1, 2025, to complement the domestic minimum top-up tax
September 13, 2024
News
Sweden: Proposed amendments to Pillar Two global minimum tax rules
Proposed amendments would introduce elements of the OECD Administrative Guidance
September 13, 2024
News
Finland: Consultation on proposed amendments to Pillar Two global minimum tax rules
Proposed amendments would apply retroactively to financial years beginning on or after January 1, 2024.
September 13, 2024
News
KPMG report: Comments on EU public consultation on template and formats for public country-by-country (CbC) reports
In response to the EC consultation, KPMG firms in the EU submitted a memo with comments.
September 11, 2024
News
Poland: Updated transfer pricing reports guidebook
The Ministry of Finance published an updated 5th edition of the transfer pricing reports guidebook.
September 11, 2024
News
UK: Compliance guidelines for dealing with transfer pricing risks
HM Revenue & Customs published compliance guidelines for dealing with transfer pricing risks.
September 11, 2024
News
Bahrain: Legislation implementing Pillar Two global minimum tax rules
Key features of the new law and an overview of how the domestic minimum top-up tax is calculated
September 5, 2024
News
Belgium: Prepayment system for Pillar Two taxes now operational
Prepayment system for domestic minimum top-up tax and income inclusion rule top-up tax is operational as of September 2, 2024.
September 3, 2024
News
Italy: Amended deadline for income tax returns, implications for transfer pricing documentation
Legislative Decree no. 108 amended the deadline for submitting income tax returns to within 10 months of the financial year end.
September 3, 2024
News
Moldova: Amendments to corporate income tax, VAT, and transfer pricing rules
Amendments to certain provisions of the Moldovan Fiscal Code with effect from January 1, 2025
August 29, 2024
News
Czech Republic: Proposed amendment to legislation introducing top-up tax, implementing EU directive on global minimum tax
A draft amendment to the law introducing a top-up tax to implement the EU directive on global minimum tax in the Czech Republic
August 27, 2024
News
Germany: Proposed investment tax incentives, Pillar Two changes, intra-group financing transfer pricing guidance, MLI law enacted
Recent tax developments in Germany
August 27, 2024
News
KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on India and South Korea
How tax authorities are approaching the control of risk and development, enhancement, maintenance, protection, and exploitation (DEMPE) frameworks
August 26, 2024
News
Australia: Proposed amendments to legislation implementing Pillar Two global minimum tax rules
The federal government proposed amendments to legislation implementing Pillar Two global minimum tax rules currently before parliament.
August 23, 2024
News
Australia: Legislation implementing Pillar Two global minimum tax rules passes House of Representatives
The bills now move to the Senate for consideration.
August 22, 2024
News
KPMG report: Potential effects on businesses of new UN tax treaty
A KPMG report that reviews the UN’s efforts to create a new tax treaty and explains why businesses need to monitor the UN process
August 21, 2024
News
Channel Islands: Pillar Two draft legislation published (Jersey)
Scheduled for debate in Jersey’s Parliament on October 1, 2024
August 19, 2024
News
KPMG report: Reassessing operations in Mexico due to maquila tax regime changes
Now is the time to analyze the impact of regulatory changes on operations
August 16, 2024
News
OECD: Transfer pricing framework for lithium
How the comparable uncontrolled price method can be applied to intragroup transactions involving lithium brines and lithium minerals
August 12, 2024
News
Australia: Updated guidance on petroleum resource rent tax implements gas transfer pricing review recommendations
Guidance applies to tax years beginning on or after July 1, 2024
August 7, 2024
News
UAE: Tax authority’s policy on issuing clarifications and directives, including advance pricing agreements
Decision No 4 of 2024 amends tax authority’s policy on issuing clarifications and directives
August 6, 2024
News
Korea: Further proposed amendments to Pillar Two rules
The Ministry of Economy and Finance announced further proposed amendments to the Korean Pillar Two global anti-base erosion minimum tax rules.
August 6, 2024
News
Australia: Senate committee report on public country-by-country reporting bill
The committee recommended that the bill be passed.
August 5, 2024
News
EU: Public consultation on template and formats for public country-by-country (CbC) reports
Feedback must be submitted by August 29, 2024
August 2, 2024
News
Belgium: Updated transfer pricing forms
Updated Local file, Master file, and country-by-country reporting notification forms
August 1, 2024
News
Austria: Public country-by-country reporting implemented, draft amendments to transfer pricing guidelines
The law applies to financial years beginning after June 21, 2024.
July 30, 2024
News
Mexico: Updated qualified maquiladora approach applies to APAs for 2020 to 2024
Updated income estimation mechanics for the years 2020 to 2024
July 29, 2024
News
Tax report to G20 Finance Ministers and Central Bank Governors; other reports on international tax reform developments
The report describes key developments in international tax reform since February 2024.
July 25, 2024
News
UN: Revised draft terms of reference for UN framework convention on international tax cooperation
A revised draft of terms of reference for a United Nations framework convention on international tax cooperation.
July 25, 2024
News
KPMG report: Employee data reporting under Pillar Two
A KPMG report that discusses how correctly reporting employee numbers, locations, and costs will benefit multinational enterprises under Pillar Two.
July 22, 2024
News
KPMG report: APMA program annual report on APA statistics for 2023
Examination of the report and insights for taxpayers
July 22, 2024
News
OECD: Selection documentation package requirements for International Compliance Assurance Programme (ICAP)
ICAP is a multilateral risk assessment program for transfer pricing and permanent establishment issues
July 18, 2024
News
Canada: Only Federal Court can review discretionary decisions of tax authority in transfer pricing matters
A Supreme Court decision concerning discretionary decisions of tax authority in transfer pricing matters
July 18, 2024
News
OECD: Consultation on GloBE information return filing standard
The OECD released a draft user guide for the GloBE information return filing standard for consultation.
July 12, 2024
News
KPMG report: Transfer pricing in Brazil
A report on how multinational enterprises must quickly work to analyze and carefully document their operations for transfer pricing purposes
July 11, 2024
News
Israel: Adjusted intellectual property (IP) valuation (District Court decision)
The court determined distinct values for each of the analytical elements in question, reaching an adjusted IP valuation.
July 11, 2024
News
Czech Republic: Acquisition structure not abusive; cost base when applying net profit margin transfer pricing method
Reports on recent tax-related Supreme Administrative Court (SAC) decisions
July 10, 2024
News
Australia: Changes to non-arm’s length income provisions for superannuation funds
The changes became effective July 1, 2024, and apply from July 1, 2018.
July 9, 2024
News
Australia: Draft legislation implementing Pillar Two global minimum tax rules introduced in Parliament
Draft legislation was referred to the Senate Economics Legislation Committee
July 9, 2024
News
Australia: Legislation clarifying “exploration for petroleum,” updating transfer pricing guidance passes Parliament
The legislation proposes tax measures that would clarify “exploration for petroleum” and update transfer pricing guidance.
July 9, 2024
News
Gibraltar: Additional tax proposals in 2024 budget, including update to Pillar Two rules
Minister for Justice, Trade and Industry addressed the Gibraltar parliament
July 3, 2024
News
Belgium: Extended deadline for GloBE registration for groups not intending to prepay to 16 September 2024
Deadline remains unchanged for groups that intend to prepay
July 2, 2024
News
Australia: ATO update on implementation of Pillar Two global minimum tax rules
Australian-specific administration and interpretation issues
July 1, 2024
News
KPMG report: Taxpayer-initiated transfer pricing adjustments in MAP
Overview of the MAP under a relevant income tax treaty as it relates to taxpayer-initiated adjustments
July 1, 2024
News
Germany: Draft bill for Annual Tax Act 2024 published, includes Pillar Two changes; other tax developments
Recent tax developments in Germany
June 28, 2024
News
Tax-exempt rental income; transfer pricing documentation with lump-sum taxation; partnership liquidation subject to VAT
A report that includes summaries of recent court decisions in Poland.
June 26, 2024
News
KPMG report: Accounting for income tax implications of Pillar Two GloBE top-up taxes
A KPMG report that discusses how implementing the new rules and determining the appropriate accounting impacts may be challenging.
June 25, 2024
News
Canada: Outstanding tax measures enacted, including Pillar Two, EIFEL, hybrid mismatch, clean economy, and GAAR
Tax measures previously proposed in the federal budgets of 2022, 2023, and 2024, as well as the 2023 federal economic update
June 24, 2024
News
Luxembourg: Draft law amending Pillar Two law introduced to Parliament
Bill 8396 amending the Pillar Two law enacted in December 2023 was introduced to Parliament on June 12, 2024.
June 20, 2024
News
KPMG report: New Amount B guidance expands on definitions
A KPMG report that discusses the June 2024 Amount B guidance.
June 20, 2024
News
KPMG report: Further guidance on Pillar Two GloBE model rules
A KPMG report that provides initial observations and analysis on the new guidance and describes additional Pillar Two guidance expected this year.
June 20, 2024
News
KPMG report: OECD unveils further details on Amount B simplified approach
The OECD published additional guidance on key definitions related to Amount B.
June 18, 2024
News
OECD: Further guidance on Pillar One Amount B and Pillar Two global minimum tax
Further information relating to Amount B of Pillar One and the global minimum tax under Pillar Two
June 17, 2024
News
Cyprus: Quality assurance review template for Local file
The tax department released the quality assurance review template for the Cyprus Local file.
June 11, 2024
News
UN: Proposed zero draft terms of reference for UN framework convention on international tax cooperation
Written comments are due by 21 June 2024.
June 10, 2024
News
India: Mere existence of subsidiary in India does not automatically constitute a permanent establishment (High Court decision)
To establish a PE, conditions outlined in applicable treaty must be met based on actual facts of the case
June 7, 2024
News
Australia: Public country-by-country reporting legislation introduced
The federal government introduced legislation to Parliament that proposes to implement public CbC reporting for multinational enterprises.
June 6, 2024
News
OECD: Updated International Compliance Assurance Programme (ICAP) FAQs
Expanded list of “frequently asked questions” (FAQs)
June 5, 2024
News
Serbia: Rulebook on arm’s length interest rates for 2024
Rulebook provides an increasing trend of interest rates compared to 2023
June 4, 2024
News
Italy: Implementation of Pillar Two transitional safe harbors
Transitional country-by-country (CbC) reporting safe harbors for groups subject to the Pillar Two global minimum tax
June 4, 2024
News
KPMG report: Assessing the impact of Amount B
Unexpected outcomes and potential challenges that businesses may need to consider
June 3, 2024
News
OECD: Updated guidance on implementation of country-by-country reporting clarifies reporting of dividends
Updates treatment of dividends to align with the Pillar Two anti-arbitrage rules as applicable to the Transitional CbCR Safe Harbor
June 3, 2024
News
OECD: Updated guidance on implementation of country-by-country reporting clarifies reporting of dividends
Updates treatment of dividends to align with the Pillar Two anti-arbitrage rules as applicable to the Transitional CbCR Safe Harbor
June 3, 2024
News
Statement by co-chairs of Inclusive Framework on BEPS indicates final negotiations on Pillar One nearing completion
The OECD released a statement by the co-chairs of the Inclusive Framework on Base Erosion and Profit Shifting.
May 30, 2024
News
Australia: House passes legislation clarifying “exploration for petroleum,” updating transfer pricing guidance
Treasury Laws Amendment (Delivering Better Financial Outcomes and Other Measures) Bill 2024
May 30, 2024
News
Japan: Explanation of guidance on income inclusion rule, associated forms and schedules
National Tax Agency explanation of guidance relating to the income inclusion rule
May 30, 2024
News
Belgium: Due date for first GloBE registration is July 13, 2024
July 13 is the due date for the first notification deadline for GloBE registration in Belgium
May 29, 2024
News
Cyprus: Final version of 2022 transfer pricing documentation form
The Cyprus tax department released the final version of the “Table of Summarised Information” form for the 2022 tax year.
May 28, 2024
News
Crown Dependencies: Details on plans to implement Pillar Two global minimum tax
All islands have expressed intention to work cooperatively, but each is adopting a different approach.
May 24, 2024
News
Australia: KPMG comments on subordinate draft legislation implementing Pillar Two global minimum tax rules
KPMG tax professionals provided a submission to Treasury on the primary legislation
May 23, 2024
News
Spain: Consultation on draft legislation implementing Pillar Two global minimum tax
Comments accepted until May 31, 2024
May 23, 2024
News
Switzerland: Cantonal tax law changes in response to Pillar Two global minimum tax
Several cantons have changed their tax rates in response to enactment of Pillar Two global minimum tax
May 22, 2024
News
Belgium: GloBE registration requirements for multinational and large domestic groups
Responsibility lies with Belgian ultimate parent entity or Belgian constituent entity
May 22, 2024
News
Poland: Consultation on Pillar Two global minimum tax rules extended
The Minister of Finance extended the draft bill implementing the EU Minimum Tax Directive to 24 May 2024.
May 21, 2024
News
Kenya: Tax proposals in Finance Bill, 2024 include implementation of Pillar Two global minimum tax
Changes to tax framework
May 16, 2024
News
Czech Republic: Transfer prices for advertising expenses; statutory rate of interest on retained VAT deductions upheld
Reports on recent tax-related Supreme Administrative Court (SAC) decisions
May 15, 2024
News
Malaysia: Updated advance pricing arrangement guidelines
Updated guidelines tighten the eligibility criteria for APA applications
May 15, 2024
News
Belgium: Amendments to Pillar Two global minimum tax rules
The Belgian Parliament adopted amendments to the Pillar Two global minimum tax rules that were adopted in December 2023.
May 3, 2024
News
KPMG report: Employee data reporting for public country-by-country reporting
Discusses how navigating complexities of public CbC reporting requires an understanding of nuances of employee data reporting
May 2, 2024
News
Norway: Pillar Two global minimum tax implemented in Supplementary Tax Act
Norway implemented the Pillar Two global minimum tax rules in the Supplementary Tax Act, which became effective 1 January 2024.
May 2, 2024
News
Slovakia: Guidelines on transfer pricing documentation for 2023
The Ministry of Finance released guidelines on the content of transfer pricing documentation for 2023.
April 30, 2024
News
OECD: Consolidated commentary on Pillar Two rules, updated Pillar Two examples
The OECD released a consolidated commentary to Pillar Two global anti-base erosion (GloBE) rules.
April 30, 2024
News
Poland: Draft bill implementing Pillar Two global minimum tax published
Provides for an income inclusion rule, qualified domestic minimum top-up tax, and undertaxed profit rule
April 29, 2024
News
OECD: Tax inspectors without borders 2024 annual report, new focus on country-by-country data and digital economy
Updates on international tax initiative to assist developing countries in boosting tax revenues and better mobilizing domestic resources
April 29, 2024
News
Poland: Public country-by-country reporting implemented
New regulations apply to income tax reports for financial years starting after 21 June 2024
April 23, 2024
News
Germany: New transfer pricing regulations for intra-group financial transactions
New rules introduced define how to interpret arm’s length principle for inbound financial transactions
April 19, 2024
News
Australia: KPMG comments on draft legislation implementing Pillar Two global minimum tax rules
KPMG tax professionals provided a submission to Treasury
April 19, 2024
News
Australia: Performance audit report on management of transfer pricing for related-party debt
The audit was done to provide assurance to the Parliament that the ATO “effectively manages transfer pricing for related party debt.”
April 18, 2024
News
Korea: Guidance regarding amendments to Pillar Two rules
The Ministry of Economy and Finance published regulations regarding the amendments to the Korean Pillar Two global minimum tax rules.
April 11, 2024
News
Cyprus: FAQs on adoption of new transfer pricing legislation
FAQs expected to be expanded with additional questions in the future
April 10, 2024
News
KPMG report: Transfer pricing and ESG—improving governance by operationalizing transfer pricing
A report that focuses on ways multinational corporations can use operational transfer pricing as a mechanism to improve compliance
April 8, 2024
News
Bahrain: Deadline for country-by-country reporting filings for FY 2023 is 31 December 2024
The Ministry of Industry and Commerce issued a letter regarding country-by-country (CbC) reporting filings for FY 2023.
April 8, 2024
News
Hungary: Audit plan for 2024 focuses on transfer pricing
New transfer pricing reporting requirement can be used for risk assessment and tax audit selection purposes in 2024
April 5, 2024
News
Australia: New 2024 reportable tax position schedule released, with new questions on intangibles migration arrangements
The Australian Taxation Office released the new reportable tax position schedule and instructions for 2024.
April 4, 2024
News
KPMG report: Recent DCL and Pillar Two guidance, comments and recommendations
Interaction of U.S. dual consolidated loss (DCL) rules and the OECD Pillar Two rules may result in unintended consequences
April 2, 2024
News
KPMG report: New UK transfer pricing guidance on allocation of risk in controlled transactions
HMRC’s guidance sets out its views on issues pertaining to the OECD Transfer Pricing Guidelines.
March 29, 2024
News
Netherlands: Public country-by-country reporting implemented
Public CbC reporting rules apply to financial years starting on or after 22 June 2024.
March 29, 2024
News
Announcement 2024-16: APMA program, APA statistics for 2023
25th report describing the experience, structure, and activities of the APMA program
March 29, 2024
News
South Africa: Comparable uncontrolled price method held most reliable method (court decision)
A court decision concerning whether comparable uncontrolled price method was the most reliable method.
March 28, 2024
News
Luxembourg: Guidance under Pillar Two law relating to inclusion of deferred tax assets and liabilities in computing ETR
Clarifications with respect to Article 53 of the Pillar Two law enacted in December 2023
March 28, 2024
News
Ireland: Tax changes for the asset management and funds industry, including Pillar Two rules
Legislative and revenue practice changes that may have an impact for funds and the asset management industry
March 25, 2024
News
Australia: Consultation on draft legislation implementing Pillar Two global minimum tax rules
Consultation on primary legislation closes 16 April 2024, and consultation on subordinate legislation closes 16 May 2024.
March 22, 2024
News
Finland: Legislation implementing Pillar Two global minimum tax
New legislation effective 1 January 2024 and introduces a Finnish domestic minimum top-up tax (DMTT)
March 21, 2024
News
KPMG report: Amount B compliance challenges
Compliance challenges associated with the Amount B consensus document
March 19, 2024
News
KPMG report: Implications of ICAP statistics
ICAP statistics and implications for businesses looking to obtain tax certainty
March 19, 2024
News
Cyprus: Draft legislation implementing Pillar Two global minimum tax rules
Draft legislation would introduce IIR and UTPR for MNEs, and harmonize the tax framework with EU directive
March 14, 2024
News
Malta: Guidance on implementation of Pillar Two global minimum tax
Guidance addresses option to defer implementation of parts of EU Directive and compliance obligation of local entities affected by EU Directive
March 14, 2024
News
Jamaica: Tax measures in 2024-2025 budget
Proposed tax changes included in budget
March 14, 2024
News
United States and Turkey announce updated digital services tax agreement
Summary of political agreement between United States and Turkey
March 12, 2024
News
Australia: Taxpayer failed to meet burden of proof in transfer pricing dispute (Full Federal Court decision)
A Full Federal Court decision concerning burden of proof in a transfer pricing dispute involving cross-border related party financing.
March 12, 2024
News
Italy: Transfer pricing requirements for investment manager exemption
Guidelines to be followed by Italian investment managers of an investment vehicle that is a subsidiary or PE of a nonresident entity
March 11, 2024
News
Australia: KPMG comments on revised draft legislation implementing public country-by-country reporting
In response to the government’s request for comments, KPMG tax professionals provided a submission to Treasury.
March 6, 2024
News
Poland: Bill implementing Pillar Two global minimum tax
The bill is expected to be passed by the Council of Ministers no earlier than in Q3
March 5, 2024
News
Cambodia: Market interest rate for related party loans; incentives for voluntary amendment of tax declarations
A notification sets market interest rates for employee loans and loans between related parties for the year 2023
March 4, 2024
News
Romania: Law implementing Pillar Two global minimum tax
Law 431/2023
January 16, 2024
News
OECD: Report to G20 Finance Ministers and Central Bank Governors, updates on developments in international tax reforms
Latest developments include BEPS initiatives, tax transparency efforts and other G20 tax deliverables
February 29, 2024
News
Cyprus: Deadline to submit 2022 return for taxpayers required to submit transfer pricing documentation extended
Deadline extended to 30 November 2024
February 29, 2024
News
Slovakia: Legislation implementing Pillar Two global minimum tax passed by Parliament
Legislation introduces a so-called “top-up tax”
February 23, 2024
News
New Zealand: No adoption of Amount B
New Zealand will not adopt the OECD’s approach to in-country baseline marketing and distribution activities under Amount B
February 22, 2024
News
Kenya: Transfer pricing developments
Key developments poised to influence transfer pricing landscape in Kenya
February 21, 2024
News
KPMG report: Overview and initial observations on Pillar One – Amount B
Overview of the OECD report on Amount B and initial observations on how multinationals can respond
February 21, 2024
News
Ethiopia: New transfer pricing rules
Substantially aligned to the OECD Transfer Pricing Guidelines
February 21, 2024
News
KPMG report: HMRC guidance on OECD’s control of risk framework
Implications that HMRC guidance has for transfer pricing policies
February 21, 2024
News
Nigeria: Migration of electronic platform for filing transfer pricing returns and country-by-country notifications
Taxpayers have until 30 June 2024 to fulfill all pending filing obligations relating to filings on TaxPro-Max.
February 20, 2024
News
Singapore: Tax measures in budget 2024 include Pillar Two global minimum tax rules
Proposals implementing Pillar Two global minimum tax rules for financial years starting 1 January 2025
February 20, 2024
News
OECD: Report on Amount B under Pillar One
Simplified and streamlined approach to the application of the arm's length principle to baseline marketing and distribution activities
February 19, 2024
News
U.S. Treasury statement regarding extended agreement on digital services taxes imposed by Austria, France, Italy, Spain, United Kingdom
Extended political agreement regarding unilateral measures concerning the imposition of digital services taxes (DSTs)
February 15, 2024
News
Australia: Revised draft legislation implementing public country-by-country reporting
Latest draft takes into consideration stakeholder feedback from the April draft legislation
February 12, 2024
News
EU: VAT treatment of transfer pricing adjustments (CJEU referral from Romania)
Questions raised will clarify VAT obligations and documentation requirements for multinational companies operating within the EU
February 12, 2024
News
KPMG report: Pillar Two implications of U.S. self-initiated transfer pricing true-ups
Examples of how U.S. entities’ transfer pricing true-ups may affect GloBE ETR in the United States or a foreign jurisdiction
February 8, 2024
News
KPMG report: Legal advice memorandum shows IRS approach to intercompany debt pricing
A report that discusses recent IRS legal advice memorandum and issue of implicit support
February 8, 2024
News
Malta: Transfer pricing guidelines
Malta Tax and Customs Administration published guidelines
February 6, 2024
News
Japan: Additional guidance on income inclusion rule
The National Tax Agency released guidance in the form of Q&As on income inclusion rule
February 5, 2024
News
Malta: Time limitation on applicability of grandfathering provision under transfer pricing rules
The applicability of the grandfathering provision is limited to three years.
February 2, 2024
News
Australia: Proposed retroactive adoption of updated OECD transfer pricing guidance
Draft legislation and supporting explanatory materials would retroactively update transfer pricing laws
February 2, 2024
News
Cyprus: Proposed increase to Local file thresholds
New thresholds would be raised to €5 million for financial transactions and €1 million for all other categories of controlled transactions
February 2, 2024
News
Indonesia: New regulations for transfer pricing documentation, MAPs, APAs
The new regulations are comprehensive and covers a number of regulations previously issued by various regulating bodies.
February 2, 2024
News
KPMG report: Europe, Middle East, and Africa (EMA) transfer pricing insights (February 2024)
A one-stop-shop for KPMG transfer pricing publications released over the past couple of months.
February 1, 2024
News
UK: Updated transfer pricing guidance on allocation of risk in controlled transactions
HM Revenue & Customs (HMRC) updated transfer pricing guidance
January 30, 2024
News
Poland: Procedure for filing transfer pricing reporting forms for acquired entities
The Ministry of Finance issued a notice regarding the procedure for submitting transfer pricing reporting forms for acquired entities.
January 30, 2024
News
OECD: Aggregated ICAP statistics
Key takeaways from the statistics
January 29, 2024
News
Colombia: New deadlines for transfer pricing documentation
Informative declaration, CbC notification, Local file, Master file, CbC report
January 26, 2024
News
KPMG report: Resurgence of transfer pricing penalties
IRS shift toward increased penalty assertion; procedural considerations for taxpayers
January 23, 2024
News
Australia: Practical compliance guideline on intangibles arrangements
The Australian Taxation Office finalized its practical compliance guideline with respect to intangibles arrangements.
January 22, 2024
News
Italy: Pillar Two global minimum tax rules implemented
Legislative decree n. 209 implemented the EU Minimum Tax Directive in Italy effective 1 January 2024.
January 18, 2024
News
Italy: New tax calendar, implications for transfer pricing documentation
Taxpayers must file income tax returns within nine months (rather than the current 11 months) of the financial year end
January 17, 2024
News
Czech Republic: Legislation introducing top-up tax, implementing EU directive on global minimum tax, now effective
The law introducing a top-up tax to implement the EU directive on global minimum tax became effective on 31 December 2023.
January 17, 2024
News
Belgium: Lower house of Parliament adopts draft law implementing public country-by-country reporting
The lower house of Parliament adopted draft law transposing EU directive on public country-by-country reporting
January 17, 2024
News
France: Tax-related provisions in finance law for 2024
Pillar Two rules and transfer pricing documentation changes
January 12, 2024
News
Korea: Amendments to Pillar Two rules enacted
The National Assembly passed the 2023 tax reform proposal, which includes amendments to the Korean Pillar Two global minimum tax rules.
January 11, 2024
News
Poland: Guidance on obligation to submit transfer pricing information, base interest rates and margin rates
The Ministry of Finance published transfer pricing guidance
January 8, 2024
News
Qatar: Extended deadline for country-by-country reports and notifications
Extended deadline is 31 January 2024
January 4, 2024
News
Effect of group membership on arm’s length interest rate on intragroup loans (Chief Counsel legal advice memorandum)
Legal advice memorandum from the Office of Chief Counsel
January 2, 2024
News
KPMG report: Pillar Two rules and the asset management industry
The rules can impose additional tax on MNE groups when the UPE is a flow-through entity.
January 2, 2024
News
Hong Kong: Consultation paper on implementation of Pillar Two global minimum tax
Income inclusion rule (IIR), undertaxed profits rule (UTPR), and domestic minimum top-up tax (DMTT)
January 2, 2024
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