Netherlands: Supreme Court clarifies interest deduction limitation rule

On March 3, 2023, the Dutch Supreme Court issued a ruling on the interest deduction limitation rule under Article 10a of the Dutch Corporate Income Tax Act of 1969. […]
Ireland: Consultation on Global minimum tax

On March 31st, 2023, the Irish Ministry of Finance released a Feedback Statement (FBS) on the Pillar Two Model Rules implementation. The FBS includes draft legislation on key elements of […]
Croatia Fiscalization 2.0 Project

Type: Legislation Croatia’s Tax Administration and Ministry of Finance have created a new financial project with the goals of modernizing the financial system, enabling VAT integration, maintaining e-Archives, online records […]
OECD public consultation on Pillar Two: How to increase tax certainty

The OECD held a virtual public consultation on the 16th of March on the compliance and tax certainty aspects of the Pillar Two global minimum tax. Representatives from interest groups, […]
Brazil: Provisional measure introducing new TP rules

On the 30th of March, the Chamber of Deputies passed the Provisional Measure n. 1.152 (“MP 1.152/22“), introducing the Arm’s Length principle and aligning the Brazilian transfer pricing rules to […]
New TP doc requirements for UK MNEs

In April 2023, the United Kingdom will implement new transfer pricing documentation regulations that align with the G20/OECD Base Erosion and Profit Shifting (BEPS) Action Plan. This change is put in place […]