As part of the Fiscal Transition Support Program in West Africa (FTSP), the OECD organized a training workshop on transfer pricing from 30 May to 1 June 2023 in Lomé, Togo, for representatives of the 15 Member States of the Economic Community of West African States (ECOWAS), the Islamic Republic of Mauritania, as well as the Commissions of ECOWAS and the West African Economic and Monetary Union (WAEMU).

This training workshop is part of a three-year training cycle on transfer pricing organized by the OECD under the FTSP and intended to train thirty tax auditors from West African countries.

The training focused on the Mutual Agreement Procedure which aims to eliminate double taxation resulting from transfer pricing upward adjustments and consisted of presentations by OECD experts alongside practical cases and role plays designed to expose the participants to concrete transfer pricing issues. Held in French, English and Portuguese, it provided opportunities for participants to share their experience for the benefit of their respective tax administrations.

On May 23, 2023, the UAE tax authority published Decision No. 126 of 2023 on the general rules for limiting the deduction of interest for corporate tax purposes.

The ruling includes provisions on the definition of interest. It states that the amount of interest that may be deducted from taxable income is the greater of AED 12,000,000 or 30% of Earnings Before Interest, Taxes, Depreciation and Amortization (EBITDA).
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This Decision came into effect the day following the date of its publication.

Vietnam has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention), which now covers around 1 850 bilateral tax treaties, underlining its strong commitment to prevent the abuse of tax treaties and base erosion and profit shifting (BEPS) by multinational enterprises.

The BEPS Convention will enter into force on 1 September 2023 for Vietnam.
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 On 1 June 2023, around 1 200 treaties concluded among the 81 jurisdictions which have ratified, accepted or approved the BEPS Convention will have already been modified by the BEPS Convention. Around 650 additional treaties will be modified once the BEPS Convention will have been ratified by all Signatories.

The governments of Guernsey, Jersey and the Isle of Man have reached a decision on a joint approach to the OECD’s Pillar Two framework, based on current international implementation of Pillar Two and discussions at the OECD.

The approach will comprise the implementation of an 'Income Inclusion Rule' and a domestic minimum tax to provide for a 15% effective tax rate for large in-scope multinational enterprises, from 2025.

The Islands will continue to work together, monitoring implementation internationally and adapt accordingly to developments which may require adjustments to our own implementation plans, and remain committed to continuing to offer attractive and globally competitive investment environments.

The Ministry of Finance today announced the release of the Green Paper on “Corporate Income Tax Strategies for The Bahamas”, which aims to solicit feedback from stakeholders on the government’s proposals to achieve greater efficiency and equity in the business tax regime and achieve alignment with global tax developments. 

The CIT strategies identified by the government in the Green Paper include four (4) options: Option 1 represents the OECD 15% compliant Pillar Two regime; Option 2 adds to Option 1 a 10% rate for other firms; Option 3 adds to Option 1 a 12% rate for firms above B$0.5 million and maintains the BLF for firms below this threshold and Option 4 applies a 15% CIT across all firms, except for those below the B$0.5 million which would attract a 10% rate.

The Green Paper contains a series of questions, intended to help with refining these options and other design features of the proposed CIT regime in the next phase of the exercise.
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Interested parties are invited to comment on the proposals by July 3, 2023.

As part of the ongoing work of the OECD/IGF partnership on base erosion and profit shifting (BEPS) in the mining program, the OECD is seeking public comments on two toolkits.

The first toolkit provides a framework that is designed to support developing countries in addressing the transfer pricing challenges faced when pricing minerals. The second toolkit applies this transfer pricing framework to a specific mineral (bauxite).

Comments on the toolkits must be received by July 14.

UAE Ministry of Finance has clarified the accounting standards and methods for corporate income tax purposes.

Decision No. 114 of 2023, which came into force on 10 May 2023, states that taxpayers may use cash accounting to prepare their financial statements if their revenues do not exceed AED 3 million, or in exceptional cases upon application to the Federal Tax Authority.
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The preparation of consolidated financial statements for tax groups requires the preparation of stand-alone financial statements derived from the aggregation of the stand-alone financial statements of the parent company and the subsidiaries of the tax group, thereby eliminating any inter-group transactions.

UK government, on April 27, announced a package of technical tax policy proposals aimed at simplifying and updating legislation on diverted profits tax and transfer pricing.

The government said that it will publish a consultation in May on simplifying and updating the following legislation: Diverted Profits Tax (DPT) (increased rate on diverted UK profits); and transfer pricing (TP) (related party transactions); among others.
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“This will ensure that their application is clear to taxpayers, and the outcome of their application remains consistent with the underlying policy intention, international standards and the UK’s bilateral treaties,” it said.