Australia updates local file and master file guidelines for 2022
On 9 August 2022, the Australian Taxation Office (ATO) updated guidance on the Local and Master file for 2022 along with instructions. The guidance applies to reporting periods beginning on or after 1 January 2021. The local file must be
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UK plans to introduce three-tiered documentation requirements
On 20 July 2022, the UK Government published draft legislation as part of the Finance Bill 2022-23 which will make it a requirement for large multinational businesses operating in the UK to keep and retain transfer pricing (TP) documentation in a
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Israel introduces three-tiered TP documentation requirements
On 30 June 2022, the Israeli Parliament passed legislation to amend Section 85A of the Income Tax Ordinance (ITO) and its regulations, by introducing three-tiered transfer pricing documentation requirements of BEPS Action 13. The legislation
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Kenya: Major changes in transfer pricing rules under Finance Act 2022
On 8 July 2022, the Kenyan Finance Act 2022 was gazetted which was signed into law by the President on 21 June 2022. The law introduced a number of changes to the transfer pricing regulatory framework in Kenya that will have far-reaching
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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 MoreKenya: Transfer pricing measures in Finance Bill 2022
On 12 April 2022, the Finance Bill 2022 was presented in the National Assembly of Kenya, which provides following tax measures related to transfer pricing. The Bill aims to amend Section 18(A) of the ITA to include transactions between residents
See MoreItaly clarifies TP documentation requirements
On 26 November 2021, the Italian Tax Authorities issued Circular No. 15 providing clarifications on the regulations introduced on 23 November 2020 regarding the content and validity of the elective transfer pricing (TP) documentation available to
See MoreTaiwan notifies affiliates of MNEs on submission of Master File and CbC report
On 9 November 2021, Taiwan’s National Tax Bureau of the Southern Area has indicated that affiliates of multinational enterprises in Taiwan, which meet the threshold to submit Master File or Country-by-Country (CbC) Report, shall not only disclose
See MoreArgentina: AFIP extends the deadline of TP filing reports
On 18 June 2021, the Federal Administration of Public Revenues (AFIP) Officially published General Resolution 5010/2021, which extends the deadline for filing transfer pricing reports and related forms F. 2668 and F. 2672 for tax years ended
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 MoreIndia: CBDT issues notification regarding CbC report and Master file
On 5 April 2021, the Indian Central Board of Direct Taxes (CBDT) has released a Notification No. 31/2021 which include the changes of CbC reporting threshold and Master file requirement. Accordingly, the threshold for CbC reporting has been
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 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 MoreGermany: Ministry of Finance publishes new transfer pricing guidance
On 3 December 2020, the Federal Ministry of Finance (BMF) has published the Administrative Principles 2020, which contain updated guidelines on audits / reviews of transfer prices between related parties and the responsibility of taxpayers to
See MoreItaly publishes new guidelines for TP documentation
On 23 November 2020, the Italian tax authority published new guidelines for transfer pricing (TP) documentation that fully replace the previous guidelines of 2010. The new guidelines implement a Ministerial Decree of 14 May 2018 that established
See MoreAustralia: ATO declares lodgment deferral for Local File, Master File, and CbC Report for FY 2019
The Australian Taxation Office (ATO) has issued a notice declaring a lodgment deferral for the Local file, Master file, and Country-by-Country (CbC) report for the year ended 31st December 2019. Significant Global Entities (SGEs) that have
See MoreGhana: Finance Minister submits new TP Regulations 2020 before Parliament
On 10 August 2020, Mr. Ken Ofori-Atta, the Minister of Finance of Ghana submitted new Transfer Pricing (TP) Regulations 2020 (L.I. 2412) before Parliament. Accordance to Article 11(7) of the Constitution of the Republic of Ghana,
See MoreHong Kong: IRD commence TP documentation compliance reviews
In September 2020, the Hong Kong Inland Revenue Department (IRD) began conducting the first round of compliance reviews of the taxpayers' transfer pricing documentation and issuing requests for information in accordance with Section 51 (4) A and 51
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