OECD: Mongolian Tax Administration issues first transfer pricing tax assessment

21 March, 2021

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

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OECD: Tax and Development Briefings

02 February, 2021

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

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France: Supreme Administrative Court makes a decision regarding TP disputes

15 January, 2021

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

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OECD: Implementation of transfer pricing for hard-to-value intangibles

19 December, 2020

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

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OECD: Transfer Pricing Implications of the Pandemic

19 December, 2020

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

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ECJ: Ruling on Transfer Pricing Treatment of Bank Transfers Between Branch and Parent

28 October, 2020

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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Poland: Council Ministers publishes draft bill amending CIT rules

28 September, 2020

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

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OECD: Phase 3 Peer Review Reports on Country by Country Reporting

24 September, 2020

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,

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Australia: Guidance on the Impact of the COVID-19 Crisis on Transfer Pricing Arrangements

23 June, 2020

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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Platform for Collaboration on Tax Launches Website

18 April, 2020

A new website has been launched by the Platform for Collaboration on Tax (PCT). The PCT is a joint initiative of the International Monetary Fund (IMF), the Organisation for Economic Co-operation and Development (OECD), the United Nations (UN), and

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Serbia: Ministry of Finance publishes safe harbor interest rates for 2020

17 March, 2020

The Serbian ministry of finance has published the Rulebook on arm’s length interest rates that are applicable for 2020, which apply to interest rates on loans and credits between associated parties. The Rulebook was published in the Official

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Dominican Republic: DGII publishes list of territories not considered tax heavens

13 February, 2020

The Directorate General of Internal Revenue (DGII) issued Notice 10-20 regarding an updated list of States that are not considered tax heaven or preferential tax regimes. The list includes the following territories: Antigua and Barbuda,

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Romania enacts EU mandatory disclosure regime (DAC6)

10 February, 2020

On 28 January 2020, the Government of Romania has published Ordinance no. 5 of 28 January 2020 in the Official Gazette for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning

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Belgium enacts EU mandatory disclosure regime (DAC6)

12 January, 2020

On 12 December 2019, the Belgian Parliament adopted legislation implementing the EU Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) and it was published in the Official Gazette on 30 December 2019. Under

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OECD: Report on Transfer Pricing in Brazil

23 December, 2019

On 18 December 2019 the OECD issued a report entitled Transfer Pricing in Brazil: Towards Convergence with the OECD Standard. This examines the differences between Brazil’s transfer pricing rules and the OECD transfer pricing guidelines with a

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Zambia presents the budget for 2020

09 October, 2019

On 27 September 2019, the Minister of Finance (MOF) presented the budget for 2020 to the National Assembly. Under the budget the following important amendments to the Income Tax Act will take effect from 1 January 2020: Corporate tax

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Portugal publishes changes to various Tax Codes

23 September, 2019

On 18 September 2019, the Portuguese Government officially published the Law no.119/2019. The new law has changed the following provisions: Corporate income tax: The procedure whereby non-resident companies may waive all or part of the

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Ireland: Finance Department publishes feedback statement regarding TP rules

12 September, 2019

In February 2019, the Finance Department carried out a public consultation on Ireland’s transfer pricing rules indicating the intended direction in respect of certain recommendations contained in the Coffey Review and seeking stakeholders

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