Botswana: General Commissioner sets TP documentation threshold
On 1 September 2021, the General Commissioner published a ruling and set a threshold for the preparation and submission of transfer pricing documentation. The ruling is effective retroactively from 1 July 2019 (2020 tax year). According to the
See MoreIndia extends the due dates for E-filing of various forms
On 29 August 2021, the CBDT published circular No. 16/2021 to extend the deadlines for the electronic submission (E-filing) of various forms. Accordingly, the due date for filing the CbC report notice (i.e. Form 3CEAC) may be submitted on or before
See MoreNigeria: FIRS suspends CbC report local filing for non-parent entities
In September 2013, the Organization for Economic Co-operation and Development (OECD) and G20 countries, working together on an equal footing, adopted an ambitious and comprehensive 15-point Action Plan to address BEPS. The Action Plan aims to
See MoreGermany updates the CbC Reporting requirements based on the Annual Tax Act 2020
The Federal Ministry of Finance recently published a notice on the current issue of the Federal Central Tax Office's newsletter, which updates the country-specific (CbC) reporting requirements due to the 2020 Annual Tax Act. As a result of the
See MoreDominican Republic: DGII invites for public comments regarding CbC reporting requirements
Recently, the Directorate General of Internal Revenue (DGII) declared a public consultation on a draft general standard regarding country-by-country (CbC) reporting. The DGII invited for public comments up to 7 September 2021. The CbC report
See MoreLuxembourg updates electronic exchange and frequently asked questions of CbC report
On 20 August 2021, Luxembourg has announced that the section "Electronic exchange - country by country (CbC) reporting" as well as the frequently asked questions relating to the CbC declaration have been updated. Please note that the frequently
See MoreColombia issues Resolution on transfer pricing return and CbC notifications
On 11 August 2021, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales-DIAN) has issued Resolution No. 000072 setting out the procedure of the submission of the transfer pricing return and CbC notification for the tax
See MoreIsrael approves three-tiered TP documentation requirements
On 5 July 2021, the Israeli Ministry of Finance announced the approval of proposed amendment to the Transfer Pricing (TP) provisions of the Israeli Income Tax Ordinance (ITO). The amendment proposal introduces the three-tiered TP documentation
See MoreDenmark: Government publishes a Bill to amend Tax Control and Assessment Act
On 23 June 2021, the Ministry of Taxation proposed a draft Bill to amend the Tax Control Act and the Tax Assessment Act (Competence for approval of the information form, etc., adjustment of the disclosure deadline for legal entities, accounting in
See MoreSri Lanka amends transfer pricing regulations
Sri Lanka has published amended Transfer Pricing (TP) Regulations that update the existing regulations of 2018. The amended regulations were published in the Official Gazette on 2 March 2021 and apply retroactively from 1 April 2020. The
See MoreOman further clarifies about suspension of CbC reporting
On 7 July 2021, Oman’s tax authority published an announcement suspending the requirement to file a country-by-country (CbC) report until further notice On 14 July 2021, tax authority clarifies that the CbC reporting suspension is applicable
See MoreJordan introduces transfer pricing rules for MNE groups
On 7 June 2021, the Hashemite Kingdom of Jordan has published Regulation No. 40 of 2021 in the Official Gazette. The Regulation has introduced transfer pricing rules for multinational entity (MNE) groups with effect from 7 July 2021. The Regulation
See MoreGreece: Government publishes a Law to introduce new tax provisions
On 18 May 2021, the Government Officially published Law 4799/2021, introducing income tax reductions and other amendments to the Greek Income Tax Code. The Act includes some of the following provisions: Transfer pricing Enterprises
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Malaysia publishes new CbCR notification guidelines using Form C
On 25 May 2021, the Inland Revenue Board of Malaysia announced on its website that starting from the year of assessment (YA) 2021, constituent entities can now furnish the Country-by-Country Reporting (CbCR) Notification using the C Form.
See MoreNigeria: FIRS issues a notice to suspend CbC reporting obligations for MNE branches
The Federal Inland Revenue service (FIRS) issued a public notice to suspend Regulation 4 of the “Income Tax (CbC Regulations) Regulations, 2018”. This public notice notifies branches and subsidiaries of Multinational Enterprises (MNEs)
See MoreKenya publishes Finance Bill 2021
On 5 May 2021, the Parliament of Kenya has published the finance bill 2021 providing the following tax measures: Reintroduce the definition of the term ‘‘Control” The definition of the term “control” was deleted with the
See MoreDominican Republic: DGII issues a Decree to amend TP rules
On 21 April 2021, the Directorate General of Internal Revenue (DGII) published Decree 256-21, which makes modification on articles 5, 7, 10 and 18 of the transfer pricing (TP) regulation, established by means of the Decree no. 78-14, of March 14,
See MoreIndia: CBDT issues notification regarding CbC report and Master file
On 5 April 2021, the Indian Central Board of Direct Taxes (CBDT) has released a Notification No. 31/2021 which include the changes of CbC reporting threshold and Master file requirement. Accordingly, the threshold for CbC reporting has been
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