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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Ukraine: President signs law to implement BEPS and other provisions

03 June, 2020

On 21 May 2020, the President of Ukraine signed Law No. 466-IX (Draft Law No.1210) “On Amendments to the Tax Code of Ukraine on Improvement of Tax Administration, Elimination of Technical and Logical Inconsistencies in Tax Legislation", which was

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Turkey: Revenue Administration issues decree on transfer pricing documentation

27 February, 2020

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

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Ukraine: Parliament approves draft law to implement BEPS provisions

10 February, 2020

On 16 January 2020, the Ukrainian Parliament approved draft laws on the improvement of the administration of taxes and elimination of certain inconsistencies in tax legislation (Law No 1209-1 and Law No 1210) to implement the Base Erosion and

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Colombia publishes a decree on tax return and TP documentation deadline

20 January, 2020

On 23 December 2019, Colombian tax authority (DIAN) has published Decree No. 2345 specifying the deadlines for filing and payment of the tax return (declaration) for 2020 and the deadline for transfer pricing (TP) documentation, including

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Qatar publishes new regulations to amend income tax law

28 December, 2019

On 11 December 2019, Qatar published Executive regulations 39/2019 in the Official Gazette, introduced new Income Tax Law No. 24 of 2018. The new regulations are generally effective from 12 December 2019. Key features of the new regulations

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Germany: Federal Ministry of Finance publishes a draft law with significant changes to TP rules

25 December, 2019

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

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Bulgaria legislates amendments to the TP documentation threshold

09 December, 2019

On 6 December 2019, the Bulgarian Government published the amendments to the Act on Tax and Social Security Procedures in the Official Gazette. According to the amendments, the obligation to prepare such documents from 1 January 2020 will not apply

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Denmark publishes the Bill no. L 48 on international taxation

30 November, 2019

On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. The bill updated the existing PE (permanent establishment) rules, CFC rules and strengthen the Transfer pricing (TP) rules. PE rules: The

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Bulgaria approves changes to the TP documentation threshold

29 November, 2019

On 21 November 2019, the Bulgarian parliament approved amendments to the thresholds for mandatory preparation of a local transfer pricing file. According to the amendments, the obligation to prepare such documents from 1 January 2020 will not

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Australia extends TP document submission deadline

18 November, 2019

Significant global entities (SGEs) that have a CbC reporting obligation in Australia for the year ended 31 December 2018 required that their local file (LF), master file (MF), and CbC report are due to be lodged by 31 December

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