Portugal publishes new transfer pricing Legislation
On 26 November 2021, the Portuguese Tax Administration (PTA) published Order No. 268/2021, which replaces Regulation No. 1446-C / 2001 of December 21, 2001. The new regulation revises the rules for implementing the arm's length principle under
See MoreZambia proposes transfer pricing changes
On 29 October 2021, the Zambian government has presented the budget for 2022 to the Parliament. The budget proposes a number of significant changes in corporate taxation including amendments to transfer pricing regulations. The budget introduces
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 MoreSri Lanka declares CbC notification deadline for FY 2021
On 25 November 2021, the Inland Revenue Department (IRD) has issued a notice as per the paragraph (e) of Regulation 6 of the Extra Ordinary Gazette Number 2217/7 dated 02.03.2021, MNE Group whose total consolidated group revenue is not less than
See MoreTaiwan: MOF reminds taxpayers for submitting MF and CbC report by December 31st
On 30 November 2021, Taiwan’s Ministry of Finance (MOF) has issued a press release as a reminder to the taxpayers for submitting Master Files (MF) and Country-by-Country (CbC) reports. The profit-seeking enterprises that meet the conditions
See MoreDenmark 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 MoreAzerbaijan modifies the Tax Code for TP, CbC Reporting, and CFC rules
On 16 November 2021, Azerbaijan has modified its Tax Code including three main changes regarding Transfer Pricing (TP), country by country (CbC) reports, and controlled foreign company (CFC) rules. The changes will be implemented from 1 January
See MoreKenya: KRA invites public comments on draft CbC reporting regulation
On 19 November 2021, Kenya Revenue Authority has opened a consultation on a country-by-country (CbC) reporting regulation. Accordingly, the National Treasury and Planning and Kenya Revenue Authority would like to inform Multinational Enterprises
See MoreAustralia extends CbC reporting deadline
On 18 November 2021, the Australian Taxation Office (ATO) announced that country-by-country (CbC) reporting entities that have a CbC reporting obligation due by 31 December 2021 will now have until 4 February 2022 to file (lodge) such CbC reporting
See MoreMexico: Congress approves Economic Package for the fiscal year 2022
On 26 October 2021, Mexican Congress has approved the tax reform for 2020 which was presented for the fiscal year 2022 which was presented on 8 September 2021. The Economic Package clarifies income tax law, value-added tax (VAT) law, excise tax
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 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 MoreColombia issues Draft Resolution to set UVT for 2022
On 8 November 2021, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales-DIAN) has issued a Draft Resolution to set out the tax unit value (Unidad de Valor Tributario – UVT) applicable for the year 2022. The UVT is
See MoreThailand introduces CbC reporting
On 15 October 2021, the Thai Revenue Department released guidance concerning the transfer pricing requirements with regard to country-by-country (CbC) reporting for accounting periods beginning on or after 1 January 2021. The guidance is referred
See MoreDominican Republic: Government establishes thresholds and filing obligation of CbC report
On 5 October 2021, the Government established specific regulations for the country-by-country report through general standard on August 2021. The general rule is aligned with the model legislation included in the OECD’s base erosion and profit
See MoreDenmark: Parliament considers bill to relax rules on TP documentation
On 6 October 2021, the Danish parliament is taking into account draft bill L 7, which proposed an amendment to the Danish Tax Control Act in order to relax the documentation requirements for transfer pricing for purely Danish transactions. The
See MoreThailand: New documentation requirement introduces Local file
On 30 September 2021, the Director-General of the Thai Revenue Department issued guidance Notification No. 407 regarding transfer pricing (TP) documentation requirements for the information and documentation for the Local file and exemption from
See MoreSerbia publishes rulebook on updating transfer pricing rules
On 1 October 2021, the Serbian Ministry of Finance has published the updated rulebook on transfer pricing. The updated rulebook includes the more detailed guidance regarding CbC report including the conditions, content, and manner of submitting
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