Colombia issues a decree on the tax return and TP documentation deadline

07 January, 2021

On 17 December 2020, the Colombian Ministry of Finance and Public Credit has issued Decree 1680 specifying the deadlines for filing and payment of the tax return (declaration) in 2021 and the deadline for transfer pricing (TP) documentation,

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Morocco: Finance Law 2021

28 December, 2020

On 18 December 2020, Morocco's Ministry of Finance has published the Finance Law for 2021 in the Official Gazette. The measures of the Finance Law generally apply from 1 January 2021. Key measures are summarized as follows: Social

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Bulgaria: Government publishes new deadline for transfer pricing documentation

18 December, 2020

On 11 December 2020, the Bulgarian Government published the amendments to the Act on Tax and Social Security Procedure Code (TSPC) in the State Gazette. The National Assembly adopted an Act amending and supplementing the TSPC. According to the

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Germany: Ministry of Finance publishes new transfer pricing guidance

14 December, 2020

On 3 December 2020, the Federal Ministry of Finance (BMF) has published the Administrative Principles 2020, which contain updated guidelines on audits / reviews of transfer prices between related parties and the responsibility of taxpayers to

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Denmark: Government publishes an Act to set the timeline for filing TP documentation

14 December, 2020

On 9 December 2020, the Ministry of Taxation Officially published L 28 Proposal for a Law No. 1835 of 8 December 2020 to establish the timeline for filing transfer pricing (TP) documentation and amends the Corporation Tax Act and various other acts

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Sri Lanka: IRD postpones Master file and CbC reporting requirements

08 December, 2020

According to the notice of 23 November 2020, considering the prevailing Covid-19 pandemic and the multiple requests made by the stakeholders to the Ministry of Finance, the requirements to submit the TP documentations of Master Files and Country by

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Italy publishes new guidelines for TP documentation

28 November, 2020

On 23 November 2020, the Italian tax authority published new guidelines for transfer pricing (TP) documentation that fully replace the previous guidelines of 2010. The new guidelines implement a Ministerial Decree of 14 May 2018 that established

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Australia: ATO declares lodgment deferral for Local File, Master File, and CbC Report for FY 2019

18 November, 2020

The Australian Taxation Office (ATO) has issued a notice declaring a lodgment deferral for the Local file, Master file, and Country-by-Country (CbC) report for the year ended 31st December 2019. Significant Global Entities (SGEs) that have

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Ghana: Finance Minister submits new TP Regulations 2020 before Parliament

10 November, 2020

On 10 August 2020, Mr. Ken Ofori-Atta, the Minister of Finance of Ghana submitted new Transfer Pricing (TP) Regulations 2020 (L.I. 2412) before Parliament. Accordance to Article 11(7) of the Constitution of the Republic of Ghana,

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Egypt: President approves unified tax procedures law

31 October, 2020

On 19 October 2020, Egyptian President Abdel Fattah El Sisi has approved a unified tax procedures law (Law no. 206 of 2020). The Law was published in the Official Gazette. The law will be applied to tax on income, added value tax, stamp duty, fees

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Israel issues draft bill to amend transfer pricing documentation requirements

18 October, 2020

On 12 October 2020, the Israeli Tax Authority (ITA) published a draft bill for public consultation, proposing to amend Section 85A of the Income Tax Ordinance (ITO) and its regulations. The proposal incorporates the principles of the OECD’s

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Turkey publishes transfer pricing General Communiqué No. 4

24 September, 2020

On 1 September 2020, the Turkish Revenue Administration has published transfer pricing General Communiqué No. 4 on disguised profit distribution in the Official Gazette No. 31231. The Communiqué explains information regarding new transfer pricing

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Hong Kong: IRD commence TP documentation compliance reviews

23 September, 2020

In September 2020, the Hong Kong Inland Revenue Department (IRD) began conducting the first round of compliance reviews of the taxpayers' transfer pricing documentation and issuing requests for information in accordance with Section 51 (4) A and 51

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Belgium: Transfer pricing deadlines for FY 2019

10 September, 2020

The Belgian taxpayers should be aware of the transfer pricing documentation requirements and the applicable deadlines to comply with the requirements. The taxpayers have an obligation to prepare and file the following transfer pricing forms if

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Chile: SII publishes new transfer pricing reporting obligations

10 September, 2020

On 31 August 2020, the Internal Revenue Service (SII) published a Resolution No. 101, which establishes the obligations for companies to submit master file (Form 1950) and local file (Form 1951) respectively. The Resolution includes both Forms. The

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Belgium updates TP documentation guidance

17 July, 2020

On 30 June 2020, the tax authorities of Belgium published Circular Letter 2020/C/88 with updated Frequently Asked Questions (FAQs) concerning transfer pricing (TP) documentation requirements i.e. the local file (LF) and master file (MF) forms, the

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Poland: Ministry of Finance further extends TP documentation deadline due to COVID 19

30 June, 2020

On 24 June 2020, the Polish Ministry of Finance announced the further extension of transfer pricing documentation deadlines due to the coronavirus pandemic. The announcement extends the local transfer pricing documentation preparation deadline as

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Argentina: AFIP extends the transfer pricing documentation deadlines

15 June, 2020

On 5 June 2020, the Federal Administration of Public Revenue (AFIP) Officially published a General Resolution No. 4733 of 4 June 2020 to file affidavits under transfer pricing rules and postpones the previous starting due dates of June declared in

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