Portugal extends the deadline to submit the TP file
On 6 July 2022, the government announced that it would extend the transfer pricing (TP) deadlines for preparation and/or submission to the tax authority. The deadline is extended from 15 July to 15 September 2022 without any accruals or
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
See MoreParaguay issues resolution on TP reporting requirements
On 7 April 2022, the tax authority of Paraguay has issued General Resolution No. 115/2022, which provides detailed rules on the preparation and submission of the transfer pricing (TP) reporting requirements as per Law No. 6380/2019 and
See MoreAngola revises number of large taxpayers required to prepare TP documentation
On 15 March 2022, the Ministry of Finance of Angola has issued Order No. 1083/22 through which the list of the large taxpayers has been revised subject to the preparation of transfer pricing (TP) documentation. The listed large taxpayers must
See MorePuerto Rico: Treasury Department clarifies guidance on transfer pricing studies
On 20 September 2021, the Puerto Rico Treasury Department (PRTD) has issued Administrative Determination (AD) No. 21-08, which amends AD No. 21-05 of 11 May 2021. The AD 21-08 clarifies guidance on submitting transfer pricing studies (TPS). AD
See MoreUkraine: MOF approves three Orders on transfer pricing and other taxes
On 20 August 2021, the Ukraine Ministry of Finance announced the issuance of three orders that approve tax clarifications/consultations on: Issues of taxation of income of non-residents, which are equated to dividends (Order â„–
See MoreDenmark proposes to reduce the TPD obligation for purely Danish transactions
On 23 June 2021, the Ministry of Finance submitted a draft bill for consultation. The bill proposed an amendment to the Danish Tax Control Act in order to relax the documentation requirements for transfer pricing for purely Danish transactions. It
See MorePoland: MOF announces a proposal to change the transfer pricing regulation
On 28 June 2021, Poland Ministry of Finance issued a plans for taxpayer-friendly amendments to the transfer pricing regulations. The following measures have been proposed under this plan. Cancellation on the preparation of transfer pricing
See MorePortugal extends CIT return submission deadline and preparation of TP documentation
According to the Order No. 191/2021-XXII of 15 June 2021, Portugal has extended the tax compliance deadlines in response to the Covid-19 pandemic, as follows: The annual corporate tax return (Modelo 22) submission and respective payment deadline
See MoreExtension of tax compliance due dates amid COVID-19 pandemic
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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 MoreMalaysia: IRBM reduces documentation submission timeline on request
On 2 February 2021, the Inland Revenue Board of Malaysia (IRBM) updated its transfer pricing guidelines including new guidance on submission of transfer pricing documentation and penalties. With the introduction of Section 113B of the ITA1967 which
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 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 MoreBulgaria: Government publishes new deadline for transfer pricing documentation
On 11 December 2020, the Bulgarian Government published the amendments to the Act on Tax and Social Security Procedure Code (TSPC) in the State Gazette. The National Assembly adopted an Act amending and supplementing the TSPC. According to the
See MoreDenmark: 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 MoreDenmark: Parliament adopts a Law regarding transfer pricing
On 3 December 2020, the Parliament adopted the draft Bill No. L 28, which proposes to implement the OECD's recommendations on permanent establishment, so that the Danish rules are brought into line with the latest international standards. The
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