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BEPS 2.0 state of play - Developments summary

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Last updated 25 May 2023

Global Transfer Pricing Review

Global Transfer Pricing Review

Transfer pricing documentation summaries by jurisdiction

TaxNewsFlash

TaxNewsFlash

Latest tax developments being reported by KPMG member firms from around the globe

2022 Articles

December 2022

22 Dec - Latvia: New reporting obligations for digital platform operators (DAC7)

22 Dec - Netherlands: 2023 Tax Plan adopted by upper house of Parliament, including DAC7, windfall profits tax on fossil sector

22 Dec - Spain: Guidance on online “intermediation” subject to digital services tax

22 Dec - KPMG report: Public consultation document under Pillar One on draft multilateral convention provisions on DSTs

21 Dec - KPMG report: Pillar Two implementation package, initial observations and analysis

20 Dec - OECD: Public consultation documents on withdrawal of DSTs under Pillar One, implementation under Pillar Two

19 Dec - Colombia: Tax reform measures include 15% minimum tax, surcharges, digital services tax

16 Dec - Belgium: New obligations of digital platform operators (DAC7)

16 Dec - Luxembourg: 2023 budget law passed by Parliament includes reverse hybrid rule changes

16 Dec - Switzerland: Parliament approves constitutional amendment to implement Pillar Two global minimum tax

16 Dec - EU: Council adopts EU minimum tax directive

15 Dec - Mexico: Limitation on deductibility of net interest held valid (court decision)

14 Dec - OECD: Exchange of information on tax rulings under BEPS Action 5

13 Dec - EU: Member states in the EU reach agreement to implement Pillar Two (updated)

9 Dec - KPMG report: Public consultation on Amount B under Pillar One, initial observations and analysis

9 Dec - Slovakia: Public country-by-country reporting implemented

9 Dec - UK: Report of national audit office on operation and implementation of digital services tax

8 Dec - OECD: Public consultation document on Amount B under Pillar One

7 Dec - Estonia: Recent tax-related developments, including reporting obligations for digital platform operators (DAC7)

6 Dec - EU: Minimum tax directive proposal removed from ECOFIN meeting agenda

6 Dec - Kenya: Country-by-country reporting multilateral competent authority agreement signed

6 Dec - Romania: Public country-by-country reporting implemented

1 Dec - Finland: Clarifications on DAC7 reporting obligations

1 Dec - Spain: Reverse hybrid mismatch rules introduced

1 Dec - United Nations: Resolution to develop new international tax cooperation framework  

November 2022

30 Nov - Germany: Law on DAC7, submitting transfer pricing documentation in tax audits, adopted by lower house of Parliament

30 Nov - Poland: Legislation implementing “public” country-by-country reporting directive announced

29 Nov - KPMG report: Key takeaways from the OECD’s 2021 mutual agreement procedure (MAP) statistics

22 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2021

22 Nov - Poland: Ratification of treaty with Georgia; MCAA for automatic information exchange under digital platform reporting rules signed

22 Nov - EU: Public country-by-country reporting implementation summary

17 Nov - UK: Autumn statement includes transfer pricing documentation changes, update on implementation of Pillar Two, increases in corporation tax and DPT rates

17 Nov - Argentina: Update on ratification of MLI

16 Nov - Denmark: DAC7 guidance

16 Nov - OECD: Comments on progress report on administration and tax certainty aspects of Amount A of Pillar One

11 Nov - KPMG report: Comments on progress report on administration and tax certainty aspects of Amount A of Pillar One

10 Nov - OECD: Jurisdictions sign MCAA for automatic information exchange under digital platform reporting rules, CRS disclosure rules

10 Nov - United States: Corporate Alternative Minimum Tax considerations and FAQs

9 Nov - Poland: Draft legislation guidelines of reporting obligations for digital platform operators (DAC7)

8 Nov - Luxembourg: Finding of illegal State aid involving application of arm’s length principle set aside (CJEU judgment)

4 Nov - Netherlands: Updated policy statement on hybrid mismatches, deduction allowed in cost-plus situations

3 Nov - Austria: Inflation relief-related tax measures, DAC7 implementation, guidance on crypto taxation, updated VAT guidelines, other tax developments

3 Nov - FinlandDraft legislation to implement DAC7

3 Nov - Germany: Draft legislation to implement public country-by-country reporting; update on Pillar Two implementation

3 Nov - Hungary: Draft legislation to implement public country-by-country reporting

October 2022

27 Oct - Australia: Public country-by-country (CbC) reporting proposed in 2022-2023 federal budget

25 Oct - Netherlands: Consultation on implementation of Pillar Two rules

20 Oct - Germany: Penalties for failure to comply with the obligation to keep or provide transfer pricing documentation compatible with EU law (CJEU judgment)

20 Oct - OECD: Report to G20 Finance Ministers and Central Bank Governors, updates on developments in international tax reforms

20 Oct - Romania: Bill implementing public country-by-country (CbC) reporting directive

19 Oct - KPMG report: Initial observations of OECD report on tax incentives and the global minimum tax

18 Oct - Mexico: Update on ratification of MLI

17 Oct - KPMG report: Comments in response to EC public consultation on the SAFE initiative

17 Oct - South Africa: MLI to enter into force 1 January 2023

14 Oct - OECD: Updated guidance on implementation of country-by-country reporting

14 Oct - Colombia: Tax proposals in draft legislation include 15% minimum tax, surcharges on certain sectors, digital services tax

14 Oct - Australia: New income tax treaty with Iceland signed, incorporating BEPS recommendations

13 Oct - Australia: Consultation paper on BEPS 2.0

13 Oct - Belgium: Tax proposals in budget 2023-2024 include 15% minimum tax

11 Oct - Hong Kong: Proposed incorporation of MLI into domestic law

7 Oct - Malaysia: Tax proposals in budget for 2023, including domestic minimum top-up tax

6 Oct - OECD: Report on tax incentives and the global minimum tax

6 Oct - OECD: Progress report on administration and tax certainty aspects of Amount A of Pillar One; public consultation

6 Oct - EU: Report on EU Parliament meeting with European Commissioner; discussion of solidarity contribution on surplus profits in fossil sector, minimum tax directive

May 2022

27 May - OECD: Tax certainty aspects of Amount A under Pillar One; public consultation

25 May - OECD: Comments on regulated financial services exclusion under Amount A of Pillar One

24 May - EU: Status regarding proposal for EU minimum tax directive

23 May - Australia: Labor party wins 2022 election, tax policies include public country-by-country (CbC) reporting

20 May - KPMG report: Comments on regulated financial services exclusion under Amount A of Pillar One

17 May - Luxembourg: FAQ on mandatory disclosure rules (DAC6)

16 May - KPMG report: Public consultation meeting on implementation framework of global minimum tax

10 May - Poland: Mandatory disclosure requirement deadlines for domestic arrangements remain extended

6 May - Malta: FAQs on mandatory disclosure rules (DAC6)

6 May - Netherlands: Considerations for companies in scope of Pillar Two rules

6 May - New Zealand: Consultation on implementation of Pillar Two rules

6 May - OECD: Regulated financial services exclusion under Amount A of Pillar One; public consultation

5 May - KPMG report: BEPS 2.0 implementation considerations for Mexico

5 May - Canada: Draft hybrid mismatch legislation

4 May - Nigeria: Summary of tax transparency reporting developments

4 May - OECD: Tax transparency in Latin America 2022

3 May - OECD: Comments on extractives exclusion under Amount A of Pillar One

3 May - KPMG report: Comments on extractives exclusion under Amount A of Pillar One

3 May - Switzerland: Tax transparency reporting statistics and global minimum tax update

2 May - UK: Additional compliance requirements under hybrid mismatch rules

2 May - UK: Transfer pricing statistics (FY 2021)

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