US: Tax Court refuses for reconsideration in transfer pricing dispute
On 26 October the US Tax Court has denied Coca-Cola’s motion for leave to file out of time a motion for reconsideration on the grounds that the application for leave would be “futile” as the court would, since the court will ultimately
See MoreUS and Turkey sign CAA regarding CbC exchange arrangement
On 24 November 2021, US and Turkey have signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. A CbC report is intended to be first exchanged with respect to Fiscal Years of MNE Groups commencing on or after 1
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 MoreTransfer Pricing Brief: December 2021
AustraliaCbC reporting requirement-Deadlines: On 18 November 2021, the Australian Taxation Office (ATO) announced that country-by-country (CbC) reporting entities that have a CbC reporting obligation due by 31 December 2021 will now have until 4
See MoreItaly clarifies TP documentation requirements
On 26 November 2021, the Italian Tax Authorities issued Circular No. 15 providing clarifications on the regulations introduced on 23 November 2020 regarding the content and validity of the elective transfer pricing (TP) documentation available to
See MoreSri Lanka declares CbC notification deadline for FY 2021
On 25 November 2021, the Inland Revenue Department (IRD) has issued a notice as per the paragraph (e) of Regulation 6 of the Extra Ordinary Gazette Number 2217/7 dated 02.03.2021, MNE Group whose total consolidated group revenue is not less than
See MoreUkraine increases thresholds of criminal liability for tax evasion
On 17 November 2021, Ukraine has published Law No. 1888-IX in the Official Gazette increasing thresholds of criminal liability for tax evasion. The changes are applicable from 25 November 2021. The new fines are given below: EvasionPrevious
See MoreOECD: Review of Property Tax Design and Reform in OECD Countries
On 30 November 2021 the OECD issued a report on property tax reform. Some detailed focus in the report is on China, which is launching pilot property tax schemes in some regions and aims to eventually introduce a wider tax on residential
See MoreTaiwan: MOF reminds taxpayers for submitting MF and CbC report by December 31st
On 30 November 2021, Taiwan’s Ministry of Finance (MOF) has issued a press release as a reminder to the taxpayers for submitting Master Files (MF) and Country-by-Country (CbC) reports. The profit-seeking enterprises that meet the conditions
See MoreUK: Responses to Consultation on Transfer Pricing Documentation
On 30 November 2021 the UK government published a summary of responses to the consultation on transfer pricing documentation held earlier in 2021. The original consultation invited comments from interested parties on whether there should be a
See MoreNigeria: FIRS extends deadline for waiver of interest and penalties on tax liabilities
On 30 November 2021, the Federal Inland Revenue Service (FIRS) made an announcement regarding waiver of interest and penalties on company tax liabilities. The deadline for submitting all outstanding returns and pay the resulting tax liabilities,
See MoreSingapore enacts Income Tax (Amendment) Act 2021
On 16 November 2021, the Income Tax (Amendment) Act 2021 came into force. The Act gives effect to 2021 Budget and non-Budget tax measures, including an extension of the enhanced loss carry-back relief scheme, enhanced deduction for donations and
See MoreDenmark approves the bill to relax rules on TP documentation
On 25 November 2021, the Danish Parliament passed Draft Law No. L7, which largely abolishes the obligation to include domestically, controlled transactions in the Transfer Pricing Documentation (TP). The draft law also specifies the requirement to
See MoreEstonia deposits new notifications under the BEPS MLI
On 25 November 2021, the Organization for Economic Cooperation and Development (OECD) has announced that Estonia deposited new notifications under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and
See MoreRussia: MOF publish clarification guidance for TP purposes
On 18 November 2021, the Russian Ministry of Finance (MoF) published a Guidance Letter No. 03-03-07/85525 clarifying that a loan is considered a controlled debt for Transfer Pricing (TP) purposes if it is granted to a Russian company by a third
See MoreOECD: New MAP statistics for 2020
On 22 November 2021 the OECD released updated mutual agreement procedure (MAP) statistics for 2020. The statistics cover 118 jurisdictions and include almost all MAP cases globally. The collection of the MAP statistics is one element in the minimum
See MoreCyprus extends the imposition of administrative fines for DAC6 reporting
On 22 November 2021, the Cyprus Tax Department has published an announcement extending administrative fines for overdue submission of DAC6 reporting. The Tax Department informs that there will be no imposition of administrative fines for overdue
See MoreUS and India reach agreement on ‘equalization levy’ digital services tax
On 24 November 2021, the United States and India concluded an agreement on a transitional approach to the treatment of the current Indian E-commerce Equalization Levy (EL) in the transition period prior to the full implementation of Pillar 1
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