Portugal publishes new transfer pricing Legislation
On 26 November 2021, the Portuguese Tax Administration (PTA) published Order No. 268/2021, which replaces Regulation No. 1446-C / 2001 of December 21, 2001. The new regulation revises the rules for implementing the arm's length principle under
See MoreMexico: Congress approves Economic Package for the fiscal year 2022
On 26 October 2021, Mexican Congress has approved the tax reform for 2020 which was presented for the fiscal year 2022 which was presented on 8 September 2021. The Economic Package clarifies income tax law, value-added tax (VAT) law, excise tax
See MoreUkraine: Cabinet of Ministers adopts new APA procedures
On 28 October 2021, the Cabinet of Ministers of Ukraine has adopted new procedures of preliminary coordination of advance pricing agreements (APAs) in controlled transactions, as a result of which agreements on preliminary coordination of pricing,
See MoreSingapore releases updated Transfer Pricing Guidelines
On 10 August 2021, the Inland Revenue Authority of Singapore published the sixth edition of its E-Tax Guide on Transfer Pricing. The most important changes are summarized as follows: Additional guidance on cost contribution arrangements (CCAs)
See MoreChina publishes simplified procedures for unilateral APAs
On 26 July 2021, the State Administration of Taxation (SAT) issued Announcement No. 24 (2021) that finalizes a simplified procedure for unilateral advance pricing arrangements (APAs), which will come into effect on 1 September 2021. An
See MoreVietnam: New APA rules come into force
On 3 August 2021, new detailed guidelines from the Vietnamese Ministry of Finance (MoF) on the Advance Pricing Agreement (APA) came into force. The guidance was published on 18 June 2021 in circular 45/2021 / TT-BTC (circular 45) and replace with
See MoreTaiwan: MOF issues Decree on cross-border bilateral, multilateral APAs under MAP
On 24 June 2021, the Ministry of Finance issued a Decree which stipulates that when tax collection authorities negotiate cross-border bilateral or multilateral advance pricing arrangements (APAs) (hereinafter referred to as "BAPAs") with the
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 MoreMalta enacts Budget Measures Implementation Act 2021
On 16 April 2021, Malta has published and enacted Act to implement Budget Measures for the Financial Year 2021and other administrative measures (Act No. XVIII of 2021). The budget measures were announced in October 2020 which came into force on
See MoreUS: IRS extends e-signature authorization for submitting APA and MAP requests
On 15 April 2021, the IRS released an updated memo on e-signature requirements extending the authorization to electronically sign a large number of IRS forms until Dec. 31, 2021, and adding a number of new forms. The original authorization was
See MoreUS: IRS releases announcement and report concerning APMAs program
On 23 March 2021, the US IRS released an advance version of Announcement 2021-6 regarding the Advance Pricing and Mutual Agreement (APMA) program’s annual report on advance pricing agreements (APAs) for 2020. This twenty-second report
See MoreCosta Rica: Ministry of Finance issues resolution on APA procedures
On 24 March 2021, the Costa Rican Ministry of Finance released a Resolution No. DGT-R-14-2021, providing new guidelines on advance pricing agreements (APAs). The resolution provides the details guidelines of APAs procedures including definitions
See MoreEcuador: National Tax Authority amends rules on submission request for APAs
On 11 March 2021, the Deputy General Director of the Internal Revenue Service (SRI) Officially issued and signed Resolution No. NAC-DGERCGC21-0000001 in Spanish, which provides several changes to the transfer pricing regime on advance pricing
See MoreGreece: AADE publishes a guide regarding the COVID-19 effects on TP issues
On 10 March 2021, the Greek Public Revenue Authority (AADE) published Circular Ε. 2054 of 10 March 2021, providing general guidance of how to deal with the adverse effects of the COVID-19 pandemic on transfer pricing issues. The guidance is
See MoreGeorgia: MOF publishes decree amending transfer pricing rules for APAs
On 2 March 2021, the Georgian Ministry of Finance published Decree No.45 amending the Georgian transfer pricing rules regarding the Unilateral Advance Pricing Agreement (APA). The decree amends the APA clauses, most importantly reducing the filing
See MoreCanada: CRA announces not to pay cost recovery charge for APAs
On 5 February 2021, the Canada Revenue Agency (CRA) announced that they will no longer require taxpayers to provide a cost recovery charge when entering the Advance Pricing Arrangement (APA) program. Previously, the charge was used to cover the
See MoreSouth Korea enacts tax revision bill for 2021
At the end of December 2020, South Korea has enacted a tax revision bill for 2021, which was passed by Korea’s National Assembly on 2 December 2020. The tax revision bill generally effective from fiscal years beginning on or after 1 January 2021.
See MoreSwitzerland: Review on international financial and tax matters of 2020
Switzerland’s Secretariat for International Finance (SIF) has published its annual review on international financial and tax matters for 2020. With respect to tax-related matters in particular, the review includes the following: Taxing
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