OECD Tax Talk looks at international tax developments
The OECD Tax Talk held on 21 February 2022 provided an updated on important elements of tax work at the OECD. Two-Pillar International Tax Package Public consultations have begun and will cover the various building blocks of Pillar One on a
See MoreSwitzerland: Review of international financial and tax developments in 2021
On 25 January 2022 Switzerland’s State Secretariat for International Financial Matters published its summary for 2021 entitled: Swiss financial and tax centre in 2021: more sustainable, more digital and in good shape despite the pandemic. The
See MoreOECD releases latest edition of the Transfer Pricing Guidelines
On 20 January 2022 the OECD released the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The latest edition of the guidelines includes changes made to the 2017 edition by reports issued by
See MoreIndia: CBDT notifies the arm’s-length pricing variation limit for 2021-22
On 29 October 2021, the Central Board of Direct Taxes (CBDT) has published Notification No. 124/2021, which provides for a tolerance limit of 1% for wholesalers and 3% in all other cases for the arm’s-length pricing determination in the
See MoreIreland: Revenue updates TP rules for some qualifying companies
On 6 September 2021, the Revenue updated its guidance to assist some qualifying companies in accordance with Section 110 regarding the application of transfer pricing (TP) rules and other issues. Under Section 110, a company be a qualifying one if
See MoreOECD: Updates to Transfer Pricing Country Profiles
On 3 August 2021 the OECD issued an updated version of some of its transfer pricing country profiles, These include new country profiles for Angola, Romania and Tunisia, and updated profiles for seventeen other countries. The updated profiles have
See MoreCanada: The Budget implementation Bill 2021 receives Royal Assent
On 29 June 2021, the 2021 Budget Implementation Act (“Bill C-30”) received Royal Assent, which includes certain tax measures that were proposed in the 2021 Federal Budget, the 2020 Fall Economic Statement, and the 2019 Federal Budget. Bill
See MoreBrazil: Executive Branch sends second phase of draft tax reform to Congress
On 25 June 2021, the Executive Branch sent the second stage of the tax reform proposal to Congress. This Tax reform includes the following changes: Government proposed to reduce the corporate income tax rate from 15% to 12.5% in 2022 and to 10%
See MoreUN: 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 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 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 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
See MorePoland: Council Ministers publishes draft bill amending CIT rules
On 16 September 2020, the Polish Council of Ministers published a draft bill amending the corporate income tax (CIT) rules to be in force from 1 January 2021. The bill includes the following tax measures; Limited partnerships in Poland are
See MoreOECD: Phase 3 Peer Review Reports on Country by Country Reporting
On 24 September 2020, the OECD published a compilation of Phase 3 peer review reports on Country by Country (CbC) Reporting under Action 13 of the action plan on base erosion and profit shifting (BEPS). The OECD/G20 Inclusive Framework on BEPS,
See MoreAustralia: Guidance on the Impact of the COVID-19 Crisis on Transfer Pricing Arrangements
On 19 June 2020 the Australian Taxation Office (ATO) posted to its website guidance entitled COVID-19 economic impacts on transfer pricing arrangements. This sets out guidance for taxpayers affected by COVID-19 who are preparing transfer pricing
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