Netherlands updates mutual agreement procedures
On 22 June 2020, the Ministry of Finance issued a decree updating the mutual agreement procedures (MAP). The decree is effective retroactively to 11 June 2020, and replaces a prior (2008) decree. The decree was updated to reflect recent
See MoreMalaysia: IRB posts FAQs on advance pricing agreement due to coronavirus pandemic
On 16 June 2020, the Malaysian Inland Revenue Board posted online FAQs on advance pricing arrangement (APA) procedures for businesses due to the coronavirus pandemic. The questionnaire covers the filing of new APA applications; the treatment of
See MoreUS: IRS announces to change the procedures for filing MAP and APA
On 11 May 2020, IRS officials announced certain modifications to procedures for filing documents under Rev. Proc. 2015-40, 2015-35 IRB 236 (mutual agreement procedure (MAP) requests), and Rev. Proc. 2015-41, 2015-35 IRB 263 (advance pricing
See MoreRussia: Draft law to revise APA procedures
In March 2020, the Russian Ministry of Finance (MoF) released an amended version of a draft law to improve tax control over prices and procedure for entering into advanced pricing agreements (APA). The draft measures are expected to be adopted in
See MoreNew Zealand: Inland Revenue announced relief regarding APA during COVID-19
The New Zealand’s Inland Revenue (IR) has announced relief regarding advance pricing agreement (APA) during the COVID-19 outbreak. Inland Revenue has assured that customers do not need to take any specific action now to ensure that their
See MoreIndia: Central Board of Direct Taxes (CBDT) publishes finance act 2020
On 27 March 2020, the Central Board of Direct Taxes (CBDT) published the Finance Act 2020 that includes measures announced as part of the Union Budget 2020-2021 and others. The measures of the Finance Act generally apply from 1 April 2020 (or
See MoreIndonesia publishes new regulations concerning advance pricing agreements
On 18 March 2020, the Indonesian Ministry of Finance released 22/PMK.03/2020 which updates the Advance Pricing Agreements (“APA”) regulations. The new regulations, effective 18 March 2020, include the following amendments: Previously
See MoreTurkey: Revenue Administration issues decree on transfer pricing documentation
On 25 February 2020, the Turkish Revenue Administration has published Presidential Decree No. 2151 in the official gazette, which amends transfer pricing documentation rules. The decree aims to set out OECD’s Base Erosion and Profit Shifting
See MoreQatar introduces directives on MAP
On 11 February 2020, Qatar's General Tax Authority (GTA) has published following six directives on the application of the mutual agreement procedure (MAP) under double taxation avoidance agreements in relation to the implementation of base erosion
See MoreCosta Rica: Ministry of Finance publishes draft resolution on APA guidelines
In December 2019, the Costa Rican Ministry of Finance released a draft resolution regarding the procedures for processing advance pricing agreements (APAs). The draft guidelines state that APA applications would need to be addressed to the
See MoreGermany: Federal Ministry of Finance publishes a draft law with significant changes to TP rules
On 10 December 2019, Germany published a draft law implementing EU anti-tax avoidance directive. The Draft Law includes significant changes to the German transfer pricing rules. The following proposed changes have been taken place under the
See MorePoland publishes a law implementing EU directive on dispute resolution and new provisions on APAs
On 14 November 2019, Poland published the Law of 26 October 2019 on resolution of disputes over double taxation and the execution of advance pricing agreements (the “Act”), which generally entered into force on 29 November 2019. The law
See MoreDominican Republic: Executive Branch submits 2020 draft budget bill to the National Congress
On 1st October 2019, the Executive Branch sent 2020 draft budget bill to the National Congress the 2020 draft budget bill for its knowledge, discussion and approval. The bill proposes measures to extend the rules on interest deduction and
See MoreUS: Tax Court issues an opinion in the case of Eaton Corp. v. Commissioner regarding APA
On 28 October 2019, the U.S. Tax Court published an order in the case of Eaton Corp. v. Commissioner related to advance pricing agreements (APAs). In that case, Eaton Corporation (P-Petitioner) and Commissioner of Internal Revenue
See MoreGermany publishes new draft of DAC 6 implementation law
On 26 September 2019, federal government of German issued a draft proposal regarding the implementation of mandatory disclosure rules pursuant to the EU’s Council Directive 2018/822 of 25 May 2018 (commonly referred to as DAC 6) into Germany’s
See MorePortugal publishes changes to various Tax Codes
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
See MoreIndia legislates Finance (No. 2) Act 2019
On 1 August 2019, India has published the Finance (No. 2) Act 2019 in the Official Gazette, which was approved by the president. The measures of the Act are in line with those presented as part of the Union Budget for 2019-20. Corporate tax
See MoreCosta Rica: MOF publishes draft resolution on advance pricing agreements (APA)
On 2 July 2019, the Ministry of Finance released a draft resolution providing rules on advance pricing agreements (APA) under the OECD transfer pricing guidelines. The resolution outlined the application procedures for approval, refusal, renewal
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