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International Tax News & Updates

Brazil, Spain updating tax treaty

4/30/2023

 
Brazil’s Finance Ministry has released a declaration, which states the government’s intention to update the existing tax treaty with Spain.

The treaty was signed in 1974. It is being updated to incorporate key BEPS measures that both nations have committed to implement.
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More details will be published once available.

OECD updates progress on tax transparency in Asia

4/28/2023

 
A report published by the OECD acknowledges progress achieved in Asia between 2009 and 2022 in implementing transparency and exchange of information (EOI) for tax purposes.

All 22 Asian members of the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) are implementing the transparency and exchange of information on request (EOIR) standard and 16 of them are committed to starting automatic exchange of financial account information (AEOI) exchanges by 2024.
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Despite wide adherence to the international standards, their effective use remains uneven in Asia. Many Asian countries are not yet members of the Global Forum and some jurisdictions still make few EOI requests or have not yet committed to implement the AEOI standard by a specific date.

EU Commission proposes new economic governance rules

4/26/2023

 
The Commission has today presented legislative proposals to implement the most comprehensive reform of the EU's economic governance rules since the aftermath of the economic and financial crisis. 

The central objective of these proposals is to strengthen public debt sustainability and promote sustainable and inclusive growth in all Member States through reforms and investment.
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The proposals address shortcomings in the current framework.

Indian Supreme Court delivers landmark transfer pricing decision

4/21/2023

 
Indian Supreme Court has ruled that the High Court is not precluded from considering the determination of the arm’s length price determined by the Income Tax Appellate Tribunal, in exercise of its powers under Section 260A of the Income Tax Act, 1961.

The court, in its decision dated April 19, held that there cannot be any absolute proposition of law that in all cases where the Tribunal has determined the arm’s length price, the same is final and cannot be the subject matter of scrutiny by the High Court in an appeal under Section 260A.
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The court ruled that the High Court should examine whether the guidelines laid down in the Act and the Rules are followed while determining the arm’s length price.

Australia consulting on public country-by-country reporting

4/14/2023

 
The government is seeking stakeholders’ views on the exposure draft legislation and accompanying explanatory material implementing a public country-by-country reporting requirement.

As part of the October 2022‑23 Budget, the government announced a transparency measure for multinational entities to prepare for public release certain tax information on a country‑by‑country basis and a statement on their approach to taxation. The measure will enhance the tax information entities disclose to the public (for income years commencing from 1 July 2023).
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The consultation runs until 28 April 2023.

Global Forum publishes new peer review reports on transparency, information exchange

4/3/2023

 
The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) has published seven new peer review reports on transparency and exchange of information on request (EOIR).

The reports pertain to six of its members (Albania, the Czech Republic, Mexico, Nigeria, Saint Lucia and Togo) and one non-member, which had previously been deemed of relevance to its work on EOIR (Nicaragua).
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More than half of the Global Forum members have now been fully reviewed in the second round of EOIR peer reviews and the ratings assigned are generally very good with 87% of the jurisdictions obtaining satisfactory overall ratings (“Compliant” or “Largely Compliant”), while 11% were assessed as "Partially Compliant" and 2% as "Non-Compliant".
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