Denmark: Government publishes an Act to set the timeline for filing TP documentation
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
See MoreThailand declares penalty relief for transfer pricing disclosure forms in response to Covid-19 pandemic
The Revenue Department of Thailand declared a reduction of the penalty from THB 200,000 to THB 5,000 for late submissions of the transfer pricing (TP) disclosure form due to Covid-19 pandemic. The reduced penalty is available for disclosure
See MoreThailand reduces transfer pricing penalty amid Covid-19 pandemic
On 9 September 2020, the Revenue Department of Thailand announced to reduce fine for the late submission of the annual transfer pricing disclosure from THB 200,000 to THB 5,000 due to the Covid-19 pandemic, provided that the transfer pricing
See MoreGreece: Parliament published two Laws to introduce various changes in transfer pricing context
On 31 July 2020 and on 29 July 2020, the Greek Parliament Officially published two Laws, L. 4714/2020 and L. 4712/2020 respectively regarding various sections of transfer pricing. The two Laws cover the following changes: Tax dispute Resolution
See MoreIceland: The Ministry of Finance and Economy presents a draft law on TPD penalties to Parliament
On 18 February 2020, the Ministry of Finance and Economy submitted a draft bill to the parliament regarding new penalties for failing to comply with transfer pricing documentation requirements. The draft law also includes an amendment to clarify
See MoreSouth Korea: National Assembly enacts tax reform bill for 2019
On 31 December 2019, South Korea’s National Assembly has enacted tax reform bill for 2019 with a number of new measures added to the existing proposals including changes in transfer pricing measures. The new and amended tax measures are
See MoreCyprus amends the company law introducing administrative penalties
On November 1, 2019, the Registrar of Companies published a notice regarding the implementation of Law 149 (1) / 2018 (the Act). The law amends company law and company law regulations with the introduction of administrative penalties on certain
See MorePortugal publishes changes to various Tax Codes
On 18 September 2019, the Portuguese Government officially published the Law no.119/2019. The new law has changed the following provisions: Corporate income tax: The procedure whereby non-resident companies may waive all or part of the
See MoreHong Kong: IRD updates penalty provisions for international tax
On 4 September 2019, the Hong Kong Inland Revenue Department updated its web page on penalty policies related to international tax matters, including fines and criminal penalties, for noncompliance with international tax obligations. The
See MoreBulgaria publishes new mandatory TP documentation requirements
On 13 August 2019, amendments to the Tax and Social Security Procedure Code (TSSPC) were published in the State Gazette. The law introduced the mandatory new transfer pricing (TP) documentation requirements in Bulgaria. Documentation
See MorePortugal approves amendments to the TP rules
On 19 July 2019, the Portuguese parliament approved Law No. 180/2019, which includes amendments to the country's transfer pricing (TP) rules. The new law changes the following rules: Abolishing the hierarchy in the selection of the transfer
See MoreQatar: GTA issues additional CbC reporting obligations
On 16 June 2019, Qatar's General Tax Authority (GTA) has issued a notice prescribing further updates and clarifications for the Country-by-Country (CbC) reporting obligations in Qatar. Key points of CbC reporting obligations are as follows:
See MoreNew Zealand: Inland Revenue publishes revised transfer pricing regime
On 29 April 2019, Inland Revenue published the final versions of the special reports on the new rules for base erosion and profit shifting (BEPS). The rules were enacted in the Taxation (Neutralising Base Erosion and Profit Shifting) Act 2018 on 27
See MoreBelgium updates TP reporting penalties
On 8 February 2019, the Belgian Federal Public Service (SPF) Finance published Circular Letter No. 2019/C/14 regarding penalties due if a taxpayer fails to fulfill its transfer pricing (TP) reporting obligations. The Circular Letter is an annex to
See MoreLithuania gazettes new Transfer Pricing rules for 2019
On 31 December 2018, the Lithuanian Official Gazette published an order for the transfer pricing (TP) rules. The new requirements generally reflect measures implementing recommendations under the OECD’s base erosion and profit shifting (BEPS)
See MoreNigeria: Alerting TP compliance regulation deadline
The Federal Inland Revenue Service (FIRS) of Nigeria declared 31st December as the last date for the taxpayers for complying the pending transfer pricing obligations and also submitting the documentations which include the disclosures of all related
See MoreThailand enacts Transfer pricing law
On 21 November 2018, Thailand's new transfer pricing law was enacted and published in the Official Gazette and will be effective from 1 January 2019, which was approved by the National Legislative Assembly in 27 September 2018. Tax assessment
See MoreDenmark: Court imposes fines for not providing timely submission of TP documents
On 19 November 2018, the Danish tax authority published an overview of a decision by the Copenhagen Court on whether a company acted in a grossly negligent act for failing to submit the timely submission of transfer pricing (TP) documents and should
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