US: Coca-Cola requests tax court to reconsider transfer pricing dispute
On 2 June 2021, the Coca-Cola Company has requested the US Tax Court to reconsider a transfer pricing tax ruling that was given on 18 November 2020. Upon examination of the company’s 2007-2009 returns, IRS found that the company’s
See MoreKenya: KRA issues public notice regarding updated resident CIT return
On 1 June 2021, Kenya Revenue Authority has published a public notice providing information on updated resident corporation tax return. The Tax Laws (Amendment) Act, 2020 amended the rate of Corporation Tax for resident persons from 30% to 25%
See MoreFrance: Government presents draft Finance Bill 2021 in the National Assembly
On 2 June 2021, Government published the amended draft Finance Bill 2021 in the National Assembly, which proposes to temporally ease conditions related to the carryback mechanism applicable to tax losses. According to the Bill, companies will be
See MoreSpain publishes a decree amending Mutual Agreement Procedure (MAP)
On 8 June 2021, the Spanish government has published a Royal Decree 399/2021 which amends the Regulation on Mutual Agreement Procedures (MAP) as approved by Royal Decree 1794/2008. The decree implements three packages of initiatives to enhance
See MoreOECD: Comments on proposed changes to the commentary on Article 9 of the OECD Model
On 3 June 2021 the OECD published comments received from interested parties in response to a public discussion draft on proposed changes to the commentary to Article 9 (associated enterprises) of the OECD Model Tax Convention. The comments will be
See MoreUAE publishes guidance on mutual agreement procedure
The Ministry of Finance (MoF) of the United Arab Emirates (UAE) has published guidance on the mutual agreement procedure (MAP), which provides a dispute resolution procedure to resolve tax treaty related disputes. MAP is designed to relieve
See MoreCyprus: Tax department issues a notice extending penalty relief for DAC6 reporting
On 3 June 2021, the Cyprus tax department has issued a notice providing an extension to the imposition of administrative fines for overdue submission of DAC6 reporting. The Tax Department informs that there will be no imposition of
See MoreArgentina: Senate approves the bill regarding progressive CIT rates
On 2 June 2021, the Senate approved the revised draft bill, which introduces new progressive corporate income tax (CIT) rates starting from 1 January 2021. It was approved by the Chamber of Duties on 20 May 2021. According to the draft Bill, the
See MoreAustria: Government publishes a Decree regarding late payment interest
On 4 June 2021, the Government published a Decree of 4 June 2021 providing the updates regarding late payment interest, suspended tax payment and others. According to the update, from 1st July 2021 to 30 June 2024, interest rate for late corporate
See MoreJordan introduces transfer pricing rules for MNE groups
On 7 June 2021, the Hashemite Kingdom of Jordan has published Regulation No. 40 of 2021 in the Official Gazette. The Regulation has introduced transfer pricing rules for multinational entity (MNE) groups with effect from 7 July 2021. The Regulation
See MoreVietnam: MoF implements new rules on Advance Pricing Agreements
On 18 June 2021, the Vietnamese Ministry of Finance (MoF) has issued Circular 45/2021/TT-BTC, which sets out new rules on Advance Pricing Agreements in Vietnam. The key measures of the Circular are listed below: Transactions covered by
See MoreIreland: Revenue updates a guidance on surcharge on undistributed income
On 10 June 2021, the Irish Revenue published an eBrief 114/21 and a manual regarding updated guidance on the surcharge on undistributed income of service companies. Section 441 Taxes Consolidation Act 1997 provides for an additional charge of
See MoreGreece: Government publishes a Law to introduce new tax provisions
On 18 May 2021, the Government Officially published Law 4799/2021, introducing income tax reductions and other amendments to the Greek Income Tax Code. The Act includes some of the following provisions: Transfer pricing Enterprises
See MoreNetherlands updates loss carry forward provision
On 4 June 2021, the Netherlands published the Decree of 21 May 2021 in the Official Gazette, which provides for the implementation of the net operating loss carry forward changes. This legislation will enter into force for fiscal years on or after
See MoreTransfer Pricing Brief: June 2021
ArgentinaTransfer pricing information return: On 30 April 2021, the Federal Administration of Public Revenue (AFIP) made an announcement that it will exceptionally extend the due date of submitting transfer pricing study and Form F. 2668 from June
See MoreColombia joins OECD International Compliance Assurance Programme (ICAP)
Recently, Organisation for Economic Co-operation and Development (OECD) has announced that Colombia joins International Compliance Assurance Programme (ICAP). ICAP is a voluntary risk assessment and assurance programme to facilitate open and
See MoreUS: Nebraska cuts top corporate tax rate
On 26 May 2021, Nebraska Gov. Pete Ricketts signed Legislative Bill 432 which provides for a reduction of top corporate income tax rates over the next two years. Accordingly, for tax years beginning on or after Jan. 1, 2022, the rate will reduce
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Malaysia publishes new CbCR notification guidelines using Form C
On 25 May 2021, the Inland Revenue Board of Malaysia announced on its website that starting from the year of assessment (YA) 2021, constituent entities can now furnish the Country-by-Country Reporting (CbCR) Notification using the C Form.
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