Chile: SII publishes new transfer pricing reporting obligations

10 September, 2020

On 31 August 2020, the Internal Revenue Service (SII) published a Resolution No. 101, which establishes the obligations for companies to submit master file (Form 1950) and local file (Form 1951) respectively. The Resolution includes both Forms. The

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Taiwan: MOF announces draft amendments to transfer pricing guidelines

26 August, 2020

On 18 August 2020, Taiwan’s Ministry of Finance (MOF) has announced draft amendments to certain transfer pricing provisions based on chapter 6 of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The

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Belgium updates TP documentation guidance

17 July, 2020

On 30 June 2020, the tax authorities of Belgium published Circular Letter 2020/C/88 with updated Frequently Asked Questions (FAQs) concerning transfer pricing (TP) documentation requirements i.e. the local file (LF) and master file (MF) forms, the

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Poland: Ministry of Finance further extends TP documentation deadline due to COVID 19

30 June, 2020

On 24 June 2020, the Polish Ministry of Finance announced the further extension of transfer pricing documentation deadlines due to the coronavirus pandemic. The announcement extends the local transfer pricing documentation preparation deadline as

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Australia updates instructions for local file 2020

26 June, 2020

The Australian Taxation Office (ATO) updated the instructions for local file. These instructions apply to the local file for 2020. This relates to reporting periods starting on or after 1 January 2019. According to the instructions, local file

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Ukraine: President signs law to implement BEPS and other provisions

03 June, 2020

On 21 May 2020, the President of Ukraine signed Law No. 466-IX (Draft Law No.1210) “On Amendments to the Tax Code of Ukraine on Improvement of Tax Administration, Elimination of Technical and Logical Inconsistencies in Tax Legislation", which was

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Turkey: Revenue Administration issues decree on transfer pricing documentation

27 February, 2020

On 25 February 2020, the Turkish Revenue Administration has published Presidential Decree No. 2151 in the official gazette, which amends transfer pricing documentation rules. The decree aims to set out OECD’s Base Erosion and Profit Shifting

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Ukraine: Parliament approves draft law to implement BEPS provisions

10 February, 2020

On 16 January 2020, the Ukrainian Parliament approved draft laws on the improvement of the administration of taxes and elimination of certain inconsistencies in tax legislation (Law No 1209-1 and Law No 1210) to implement the Base Erosion and

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Colombia publishes a decree on tax return and TP documentation deadline

20 January, 2020

On 23 December 2019, Colombian tax authority (DIAN) has published Decree No. 2345 specifying the deadlines for filing and payment of the tax return (declaration) for 2020 and the deadline for transfer pricing (TP) documentation, including

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Qatar publishes new regulations to amend income tax law

28 December, 2019

On 11 December 2019, Qatar published Executive regulations 39/2019 in the Official Gazette, introduced new Income Tax Law No. 24 of 2018. The new regulations are generally effective from 12 December 2019. Key features of the new regulations

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Bulgaria legislates amendments to the TP documentation threshold

09 December, 2019

On 6 December 2019, the Bulgarian Government published the amendments to the Act on Tax and Social Security Procedures in the Official Gazette. According to the amendments, the obligation to prepare such documents from 1 January 2020 will not apply

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Bulgaria approves changes to the TP documentation threshold

29 November, 2019

On 21 November 2019, the Bulgarian parliament approved amendments to the thresholds for mandatory preparation of a local transfer pricing file. According to the amendments, the obligation to prepare such documents from 1 January 2020 will not

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Australia extends TP document submission deadline

18 November, 2019

Significant global entities (SGEs) that have a CbC reporting obligation in Australia for the year ended 31 December 2018 required that their local file (LF), master file (MF), and CbC report are due to be lodged by 31 December

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Costa Rica publishes a resolution outlining guideline on transfer pricing documentation

17 November, 2019

On 13 November 2019, the Costa Rican tax authority released a Resolution No.DGT-R-49-2019 providing new guidelines on transfer pricing documentation including master file and local file. The new resolution repeal the resolution DGT-R-16-2017

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Bulgaria submits proposal to amends the TP documentation threshold

13 November, 2019

On 12 November 2019, some of policy makers submitted to Parliament a proposal to amend the rules on thresholds for the Transfer Pricing (TP) documentation rules. It is proposed that the obligation to prepare such documents will not apply to persons

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Saudi Arabia: GAZT requests for TP documentation

16 September, 2019

Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia have requested the taxpayers to submit specific transfer pricing (TP) documentation (master file and local file) in relation to the fiscal year ending 31 December

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Bulgaria publishes new mandatory TP documentation requirements

16 August, 2019

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

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Bulgaria approves new mandatory TP documentation requirements

08 August, 2019

On 31 July 2019, the National Assembly approved at second (final) reading amendments to the Tax and Social Security Procedure Code (TSSPC), which introduced the new transfer pricing (TP) documentation requirements. New rules for TP

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