Within the framework of the BEPS 2.0 project, the report on Pillar One – Amount B (“Report on Amount B” or “the Report”) was published on 19 February 2024 and incorporated as an Annex to Chapter IV of the OECD Transfer Pricing Guidelines (for further details, please see our previous newsletter). Two supplements to the […]
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Within the framework of the BEPS 2.0 project a preliminary report on Pillar One – Amount B (launch version) was published on 19 February 2024 as a response to the public consultation documents (December 2021 & July 2023). The final report, including the outstanding work currently being completed, was expected by the end of March […]
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Under the BEPS 2.0 project the OECD published another public consultation document on Amount B of Pillar One on 17 July 2023. Stakeholders were invited to provide input until 1 September 2023. The declared goal of Amount B is to simplify and streamline the application of transfer pricing regulations for baseline marketing and distribution activities, […]
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On 5 May 2022, the Austrian Federal Ministry of Finance (“BMF”) published new guidance on mutual agreement procedure (“MAP”) and arbitration procedure (BMF – IV/8, Geschäftszahl 2022-0.300.851). The guidance replaces a BMF guidance from the year 2019 and provides an overview of the formal and material requirements for these procedures in Austria. Structure of the guidance […]
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The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD Transfer Pricing Guidelines) provide orientation when applying the arm’s length principle. On 20 January 2022, the OECD published a new version of these Transfer Pricing Guidelines. It is available in English and French on the OECD website. The OECD Transfer Pricing Guidelines 2022 replace […]
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On 21 December 2021, a new EU Directive (“Directive (EU) 2021/2101”) entered into force, amending the EU Accounting Directive. Under the Directive, companies are required to publish a so-called “report on income tax information” (also referred to here as “Public CbCR”). The goal of Public CbCR is to introduce an instrument for increasing transparency and enhancing […]
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Almost a year after the publication of the draft Transfer Pricing Guidelines, on 7 October 2021 the Austrian Federal Ministry of Finance has finally issued the new Austrian Transfer Pricing Guidelines (ATPG 2021 or Guidelines). Being an extensive revision of the Transfer Pricing Guidelines from 2010 (TPG 2010), the ATPG 2021 aim at reflecting BEPS-project […]
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