UN: Third edition of the Practical Manual on Transfer Pricing for Developing Countries
Following approval at the twenty-second session of the UN Committee of Experts on International Cooperation in Tax Matters, held from 19 to 28 April 2021, the UN has published the third edition of its Practical Manual on Transfer Pricing for
See MoreUS: IRS publishes revised CFC practice unit guidelines
On 22 March 2021, the U.S. Internal Revenue Service has published a revised international practice unit on Receipt of Dividends or Interest from a Related CFC. This Unit was revised to include the extension of the IRC 954(c)(6) look through rule
See MoreOECD: Profiles for Countries Applying Arbitration under the MLI
On 23 March 2021 the OECD published Arbitration Profiles for 30 jurisdictions that are applying the arbitration provisions in Part VI of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit
See MoreMorocco declares maximum interest rate 1.63% on shareholder loans
On 18 March 2021, Morocco has published Ministerial Decree 423.21 in the Official Gazette regarding the reduction of maximum interest rate for loans granted by direct shareholders from 2.23% to 1.63% for FY 2021. Interest expense on loans will
See MoreOECD: Mongolian Tax Administration issues first transfer pricing tax assessment
The OECD reported on 18 March 2021 that following the implementation of initiatives in mining tax audit capacity building the Mongolian Tax Administration issued its first assessment related to transfer pricing in late 2020. The Mongolian Tax
See MoreGreece: Tax Authority describes interest deduction limitation rules
On 11 January 2021, the Greek Public Revenue Authority (AADE) published Circular Ε. 2004 of 11 January 2021, which describes the application of the rule of limitation of interest as amended from 1 January 2019. According to the Circular, the
See MoreIreland: Revenue issues eBrief regarding guidance on CFC rules
On 12 February 2021, the Irish Revenue issued eBrief No. 027/21, which provides updated guidance regarding controlled foreign company (CFC) rules. On the similar day, the Revenue also published a Tax and Duty Manual, providing guidance of how to
See MoreTurkey issues Decree as to restriction on the deduction of financial expenses
On 3 February 2021, the Turkish Revenue Administration has published Presidential Decree No. 3490 in the Official Gazette introducing a restriction on the deduction of financial expenses. Restriction on the deduction of financial expenses rules was
See MoreSouth Africa: Government Officially publishes 2020 Tax Amendment Acts
On 20 January 2021, the Treasury Department Officially published the 2020 Tax Amendment Acts. The following Amendment Acts were promulgated: Rates and Monetary Amounts and Amendment of Revenue Laws Act 22 of 2020.Taxation Laws Amendment Act 23
See MoreOECD: Tax and Development Briefings
On 29 January 2021, to mark the annual Tax and Development Day, the OECD hosted a series of briefings in relation to tax and development, looking at OECD work in the area. BEPS and the extractive industries For decades many resource-rich
See MoreFrance: Supreme Administrative Court makes a decision regarding TP disputes
Recently, the Supreme Administrative Court made a decision of a case “France vs Ferragamo France” against of Administrative Court. On 23 November 2020, the Administrative Court made a decision in this case in favour of Ferragamo and dismissed
See MoreIreland: President signs the Finance Bill 2020 into Law
On 19 December 2020, the President signed the Finance Bill 2020 into Law, which underpins the Government’s support for the economy in the face of Covid-19 pandemic and the ongoing threat of a no-deal Brexit. The Finance Act 2020 provisions
See MoreGreece: AADE publishes preferential tax regime status for the 2019
On 7 December 2020, the Greek Public Revenue Authority (AADE) published Circular No. A.1267 of 7 December 2020, which determines the states that have a preferential tax regime based on the provisions of par. 6 and 7 of article 65 of law 4172/2013
See MoreUkraine: Parliament accepts changes to recently implemented BEPS legislation
On 17 December 2020, the Ukrainian Parliament has accepted a tax reform bill, which contains important changes to recently implemented BEPS legislation. The following important changes were introduced related to recently implemented BEPS and other
See MoreAustria: Parliament approves winter package due to COVID-19 pandemic
On 17 December 2020, the Parliament approved the COVID-19 Tax Measures Act. Recently, the Ministry of Finance has announced the draft winter package on tax measures for the coronavirus outbreak. The package includes the measures to introduce the
See MoreOECD: Implementation of transfer pricing for hard-to-value intangibles
On 16 December 2020 the OECD published information setting out the extent to which member countries of the Inclusive Framework have implemented the recommendations on hard to value intangibles (HTVI) drawn up as part of the OECD/G20 project on base
See MoreOECD: Transfer Pricing Implications of the Pandemic
On 18 December 2020 the OECD issued Guidance on the transfer pricing implications of the COVID-19 pandemic. This looks at the impact of the pandemic on areas of the transfer pricing analysis and APAs. Comparability analysis The pandemic and
See MoreECJ: Ruling on Transfer Pricing Treatment of Bank Transfers Between Branch and Parent
On 8 October 2020 the European Court of Justice (ECJ) ruled on Romania’s transfer pricing rules in relation to bank transfers from a branch to a head office that is located in another EU Member State. Impresa Pizzarotti concluded two loan
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