Denmark approves the bill to relax rules on TP documentation
On 25 November 2021, the Danish Parliament passed Draft Law No. L7, which largely abolishes the obligation to include domestically, controlled transactions in the Transfer Pricing Documentation (TP). The draft law also specifies the requirement to
See MoreRomania revises number of large taxpayers required to prepare TP documentation
On 29 October 2021, the Romanian National Tax Agency (NTA) published Order No. 1721 that revises the list of large taxpayers those are subject to prepare transfer pricing (TP) documentation. There are currently 2,940 large taxpayers until 31
See MoreItaly launches public consultation on draft circular on TP documentation requirements
The Italian tax authorities have introduced a public consultation on the draft circular clarifying transfer pricing (TP) documentation requirements. Comments should be submitted by 12th October 2021 to the email
See MoreMexico: Executive Branch submits 2022 economic proposal to Congress
On 8 September 2021, the Mexican Executive Branch has submitted Economic Package for the fiscal year 2022 including a proposal of Tax Reform. The proposed 2022 Tax Law clarifies income tax law, value-added tax (VAT) law, excise tax (duty)
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 MoreQatar releases FAQs on TP documentation requirements
Qatar’s General Tax Authority (GTA) has issued frequently asked questions (FAQs) regarding Transfer Pricing Declaration, Master File, and Local File on the Dhareeba tax portal. The FAQs provide clarification on several tax issues relating to
See MoreDenmark: Supreme Court makes a decision on a case regarding TP documentation
On 26 April 2021, the Danish Supreme Court issued its decision in a landmark transfer pricing case: Denmark v Tetra Pak Processing Systems A/S , in which a Danish company (Tetra Pak) that produced and sold plants for manufacturing ice cream. The
See MoreQatar introduces new TP documentation requirements
On 16 July 2020, the General Tax Authority (GTA) of Qatar has issued Decision No. 4 of 2020 and made public on 1 March 2021, which confirms the obligation to submit the transfer pricing (TP) disclosure form, master file, and local file applies to
See MoreQatar introduces TP declaration with tax return
The General Tax Authority (GTA) of Qatar has confirmed that taxpayers filing their income tax returns via the tax authority’s Dhareeba tax portal must also file a transfer pricing (TP) declaration of related-party transactions along with their
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 MorePhilippines: BIR issues guidance on TP reporting and documentation requirements
On 18 December 2020, the Bureau of Internal Revenue (BIR) published a Revenue Regulations (RR) No. 34-2020, which replaces the previous Revenue Regulations (RR) No. 19-2020, its clarifying Revenue Memorandum Circular No. 76-2020, and other relevant
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 MoreLithuania publishes new transfer pricing requirements
On 19 October 2020, the Ministry of Finance in Lithuania published new transfer pricing documentation requirements. The new requirements for transfer pricing documentation correspond to the recommendations of OECD base erosion and profit shifting
See MoreDenmark: High Court makes a decision against tax authority’s TP approach
On 5 October 2020, the High Court made a decision on a case entitled “Denmark vs. Shoe Group A/S” against the tax administration’s transfer pricing (TP) approach. The tax administration of Denmark used various theories to claim that a
See MoreTurkey publishes transfer pricing General Communiqué No. 4
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
See MoreSingapore publishes transfer pricing guidance in response to the Covid-19 outbreak
On 8 September 2020, the Inland Revenue Authority of Singapore updated its website by including guidance regarding transfer pricing in response to the Covid-19 pandemic. The guidance is provided in a following question and answering
See MorePoland clarifies the treatment of dividends under TP rules
On 6 August 2020, the Polish Ministry of Finance has issued a guidance on whether a dividend payment among related entities falls within the scope of the definition of a “controlled transaction” for transfer pricing purposes. The uncertainty
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