Peru: SUNAT issues guidance on comparability analysis using multi-year data
On 29 April 2021, the Peruvian tax authorities (SUNAT) has issued Administrative Guidance No. 036-2021-SUNAT/7T0000 providing guidance in relation to the use of multi-year data in determining arm's length transfer pricing. The guideline provides
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 MoreDominican Republic: DGII declares public consultation to amend TP rules
On 1 March 2021, the Directorate General of Internal Revenue (DGII) made an announcement of launching a public consultation on the draft modification of articles 5, 7, 10 and 18 of the transfer pricing (TP) regulation, established by means of the
See MoreParaguay introduces new guidance on TP law
On 30 December 2020, the tax authority of Paraguay issued Decree 4644/2020, providing further guidance on the technical aspects of Paraguay’s transfer pricing (TP) provisions included in Law 6380. Law No. 6,380/2019 modernized the Paraguayan
See MoreSingapore updates indicative margins for related party loans
The Inland Revenue Authority of Singapore (IRAS) has published updated indicative margins for related party loans. IRAS has introduced an indicative margin which taxpayers can apply on each related party loan not exceeding S$15 million as tabulated
See MoreTaiwan: MOF amends transfer pricing provisions for profit-seeking enterprises
On 28 December 2020, Taiwan’s Ministry of Finance (MOF) has announced amendments to certain transfer pricing provisions based on chapter 8 to 10 of the OECD Transfer Pricing Guidelines for profit-seeking enterprises. The key amendments are
See MoreThailand publishes new transfer pricing regulation
On 6 November 2020, Mr. Apisak Tantivorawong, the Minister of Finance issued Ministerial Regulation No. 369, published in the official bulletin 2556. The regulation sets basic rules to be followed by the tax authority when evaluating transactions
See MoreVietnam: MoF issues new transfer pricing Decree
On 5 November 2020, the Vietnamese Ministry of Finance (MoF) has issued new transfer pricing Decree No. 132/2020/ND-CP. The new Decree replaces the existing Transfer Pricing (TP) regulations (Decree No. 20/2017/ND-CP) and provides the following new
See MoreIndia issues notification on transfer pricing tolerance range for 2019–20
On 19 October 2020, India’s Central Board of Direct Taxes has released the Notification No. 83/2020 setting the arm’s length pricing variation limit for assessment year 2020-21. Accordingly, the variation between the arm’s length price
See MoreOECD: Tax Talk Summarises Latest Tax Developments
In a Tax Talk on 12 October 2020 the OECD gave an update of recent developments. Digital Economy The OECD’s Inclusive Framework met on 8 and 9 October 2020 and Blueprint reports on Pillar 1 and Pillar 2 of the proposals on taxation of the
See MoreTaiwan: MOF announces draft amendments to transfer pricing guidelines
On 18 August 2020, Taiwan’s Ministry of Finance (MOF) has announced draft amendments to certain transfer pricing provisions based on chapter 6 of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The
See MoreEcuador: The Internal Income Service amends prior Resolutions regarding transfer pricing
On 1 July 2020, the Government published Resolution No. NAC-DGERCGC20-00000046 of 1 July 2020, which amends the calculation of profit level indicators. According to amendments, it is provided that taxpayers must use the last financial information
See MoreBelgium: TP Circular on OECD guidelines
On 25 February 2020, the Belgian tax authorities published the final version of the transfer pricing (TP) Circular No. 2020/C/35 in French on their website on transfer pricing guidelines for multinational enterprises and tax
See MoreArgentina: AFIP announces draft transfer pricing guidance for public comments
On 2 October 2019, tax authority of Argentina (AFIP) announced a public consultation and posted on the AFIP website a draft resolution concerning transfer pricing compliance procedures. It would replace the existing transfer pricing rules in
See MoreIndia: CBDT issues Notification on transfer pricing arm’s length tolerance range
On 13 September 2019, the Central Board of Direct Taxes (CBDT) published Notification No. 64/2019, which sets a tolerance range for the variation between the arm’s length price and the transaction price for the 2019-20 assessment year. The
See MorePoland publishes explanatory note addressing transfer pricing comparability analyses
On 19 June 2019, Poland Ministry of Finance published an explanatory note addressing transfer pricing comparability analyses. Accordingly, database for comparables could be selected locally, regionally, or even globally by considering
See MoreSaudi Arabia: GAZT holds seminar to simplify the transfer pricing regulations
On 17 June 2019, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia has organized a transfer pricing seminar in Riyadh to simplify the key areas of the transfer pricing (TP) regulations published on 15 February 2019 and to address
See MoreMexico: Tax Administration Service publishes Q&As with respect to transfer pricing comparability adjustments
On 29 March 2019, the Mexican Tax Administration Service published, on its website, frequently asked questions (Q&As) regarding transfer prices with respect to comparability adjustments. However, 15 January 2019 in Mexico City Government
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