On 16 September 2021, the Hashemite Kingdom of Jordan has published Executive Instructions No. 3 of 2021 regarding new transfer pricing (TP) rules for MNE groups. Jordan has published Regulation No. 40 of 2021 On 7 June 2021 which introduces transfer pricing rules for MNE groups. The new Instructions introduces the following rules related to transfer pricing provision:
Transfer pricing information return
Taxpayers with related party transactions equal to JOD 500,000 or more in a 12-month period are required to submit a transfer pricing disclosure with the annual tax return.
CbC reporting requirement
Multinational Enterprises (MNEs) exceeding consolidated revenue exceeding a JOD 600 million in the previous year, will be required to submit a CbC (Country-by-Country) report. The CbC report must be submitted within 12 months after the end of the tax year.
Master file and Local file
Master file and Local file must be submitted within 12 months after the end of the tax year including detailed information provided in the Executive Instructions.
Transfer pricing methods
Taxpayers must specify the reasons for selecting the TP method and the assumptions that have been accepted. Taxpayers must submit an affidavit from a certified accountant confirming the consistent application of the transfer pricing policy of the group.
