Azerbaijan plans to increase CbC reporting penalty
On 16 November 2022, Azerbaijan submitted a proposal to the Parliament to increase the penalty for failure to submit country-by-country (CbC) reports. Accordingly, penalties for failure to file CbC reports or to comply with other CbC-related
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Belgium notifies TP penalties first time
The Belgian tax authorities have sent out the first penalty notifications for noncompliance to submit transfer pricing (TP) forms. Generally, TP documentation requirements is mandatory for Belgian entities exceeding the respective thresholds and
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Germany: CJEU has issued a decision on sanctions for non-compliance with TP documentation requirements
On 13 October 2022, the Court of Justice of the European Union (CJEU) ruled in case: C-431/21 on sanctions for non-compliance with transfer pricing (TP) documentation requirements. Under German law, there is a rebuttable presumption that the
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Hungary gazettes the 2023 Budget bill including transfer pricing changes
On 27 July 2022, the Hungarian Official Gazette published the Budget Bill (Law XXIV of 2022) providing for amendments to the Hungarian transfer pricing regulations. The law was passed by the parliament on 19 July 2022. The law includes the following
See MoreHungary: Parliament adopts a bill imposing additional requirement for TPD
On 19 July 2022, the Hungarian Parliament passed a bill introducing important changes to the transfer pricing rules. The law introduces a significant additional reporting requirement for intra-group transactions and requires transfer pricing
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Cyprus: Parliament adopts new transfer pricing legislation
On 30 June 2022, the Cyprus House of Representatives enacted detailed transfer pricing legislation amending the Cyprus Income Tax Law (ITL) and the issuance of Regulations. The amendment includes the new TP documentation requirements and a framework
See MoreDenmark introduces new filing requirements for TP documentation
Recently, the Danish Ministry of Finance introduced an obligation to file a transfer pricing documentation (TPD) with the Danish Tax Authorities on an annual basis. For the financial years beginning on or after 1 January 2021, the new law requires
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South Korea enacts tax revision bill for 2022
In December 2021, South Korea has enacted a tax revision bill for 2022 which was passed by Korea’s National Assembly on 2 December 2021. The tax revision bill is generally effective from fiscal years beginning on or after 1 January 2022. The
See MorePanama amends CbC reporting penalties
On 11 November 2021, Panama published Law No. 254 in the Official Gazette No. 29413-A, which amends the legislation on international tax transparency and the prevention of money laundering, and the financing of terrorism. The significant
See MoreAzerbaijan modifies the Tax Code for TP, CbC Reporting, and CFC rules
On 16 November 2021, Azerbaijan has modified its Tax Code including three main changes regarding Transfer Pricing (TP), country by country (CbC) reports, and controlled foreign company (CFC) rules. The changes will be implemented from 1 January
See MoreIceland publishes a law on new penalties for transfer pricing documentation
On 15 June 2021, Iceland published Law 61/2021 in the Official Gazette introducing new rules for the imposition of fines on taxpayers who fail to comply with transfer pricing documentation requirements for related party transactions, whether
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 MoreMalta introduce penalties for non-compliance with the CbC reporting rules
On 18 May 2021, Malta has issued Regulations (L.N. 213 of 2021) named ‘Cooperation with Other Jurisdictions on Tax Matters’. The Regulation has introduced penalties for non-compliance with Maltese country-by-country reporting (CbCr) reporting
See MoreIreland: Revenue issues an eBrief to announce updated TP guidance
On 24 February 2021, the Irish Revenue issued eBrief No. 37/21 regarding updated guidance on transfer pricing. On the similar day, the Revenue also published a Tax and Duty Manual-Part 35A-01-01, providing updated guidance on the operation of the
See MoreAlgeria: Government publishes revised TP documentation requirements
On 2 January 2021, Government Officially published a Decree of 17 November 2020, which replaces the Decree of 12 April 2012. Initial transfer pricing documentation, which is submitted with the tax return, includes: Basic documentation regarding
See MoreMorocco revises TP documentation penalty
On 18 December 2020, the Ministry of Finance of Morocco has published the Finance Law for 2021 in the Official Gazette, apply from 1 January 2021. Morocco's Finance Law 2021 introduced new transfer pricing (TP) documentation
See MoreEgypt makes some changes to the Unified Tax Procedure Law
On 3 December 2020, Egypt has published Law No. 211 in the official gazette. The Law makes some important changes to the recently published Unified Tax Procedure Law (Law no. 206 of 2020). The new Law mainly changes transfer pricing non-compliance
See MoreMalaysia: The Finance Bill 2020 includes transfer pricing measures
On 16 November 2020, Malaysia issued the Finance Bill 2020 (Bill No. DR 17/2020) including following proposals related to transfer pricing provision. Penalties for failure to prepare transfer pricing documentation There is currently no
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