Russia declares country names for exchange of CbC Report

23 December, 2020

On 10 December 2020, Russia has published an order of the Federal Tax Service amending the list of Territories and States with which Russia will automatically exchange Country-by-Country (CbC) reports. The Order entered into force on 21

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Egypt makes some changes to the Unified Tax Procedure Law

23 December, 2020

On 3 December 2020, Egypt has published Law No. 211 in the official gazette. The Law makes some important changes to the recently published Unified Tax Procedure Law (Law no. 206 of 2020). The new Law mainly changes transfer pricing non-compliance

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Peru: SUNAT publishes frequently asked question on CbC Report

21 December, 2020

On 16 December 2020, the Peruvian tax authorities (SUNAT) has released frequently asked questions (FAQ) in Spanish providing an elaborate description of country-by-country (CbC) reporting, including the format of CbC report, local filing

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Cyprus: Tax department extends CbC reporting deadline to 31 January 2021

21 December, 2020

On 15 December 2020, the Cyprus Tax Department announced an extension to the reporting deadline for country-by-country reports for the year 2019 and notifications for the year 2020. The reporting deadline for submission of country by country

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Bulgaria: Government publishes new deadline for transfer pricing documentation

18 December, 2020

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

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Malaysia: The Finance Bill 2020 includes transfer pricing measures

15 December, 2020

On 16 November 2020, Malaysia issued the Finance Bill 2020 (Bill No. DR 17/2020) including following proposals related to transfer pricing provision.   Penalties for failure to prepare transfer pricing documentation There is currently no

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Germany: Ministry of Finance publishes new transfer pricing guidance

14 December, 2020

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

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Denmark: Government publishes an Act to set the timeline for filing TP documentation

14 December, 2020

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

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Poland publishes law amending corporate income tax act

11 December, 2020

On 30 November 2020, the act amending the Corporate Income Tax Act was published in the Polish Journal of Laws and thus entered into force. The amendment introduces compliance of limited partnership having their management or registered office in

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Denmark: Parliament adopts a Law regarding transfer pricing

10 December, 2020

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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Finland: Tax authority publishes CbC reporting XML schema version 2.0

09 December, 2020

On 4 December 2020, the Finnish tax authority has updated its CbC reporting guidance concerning changes in the Country-by-Country (CbC) reporting XML schema to Version 2.0. Version 2.0 (Country-by-Country Reporting XML Schema 2.0) is released by

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Sri Lanka: IRD postpones Master file and CbC reporting requirements

08 December, 2020

According to the notice of 23 November 2020, considering the prevailing Covid-19 pandemic and the multiple requests made by the stakeholders to the Ministry of Finance, the requirements to submit the TP documentations of Master Files and Country by

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Ireland: Revenue updates CbC user guide

08 December, 2020

On 30 November 2020, the Irish Revenue published an eBrief 216/20 on a new Tax and Duty Manual Part 38-03-21, which provides details of the release of CbC User Guide Version 2.0 and CbC XML Schema Version 2.0, which will be in use from 1 February

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Malta: CFR updates CRS and CbC XML schema and user guide

07 December, 2020

On 30 November 2020, the Maltese Commissioner for Revenue (CFR) notified that the cut-off date for the version change of the CRS and CbC XML schemas for any domestic reporting is 10 January 2021. Any CRS and CbC XML data files submitted after this

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Peru: SUNAT extends CbC reports submissions deadline for FY 2017, 2018 and 2019

05 December, 2020

On 2 December 2020, the Peruvian tax authorities (SUNAT) has declared that the deadlines for the secondary local (Peruvian) filing of the country-by-country (CbC) reports for fiscal years (FY) 2017, 2018, and 2019 is 29 January 2021. The

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Sri Lanka: TP documentation requirement for domestic controlled transactions

05 December, 2020

According to the notice of 25 November 2020, under the Regulation 1 of the TP Gazette, transfer pricing regulations inter alia, are applicable to the local transactions made between associated enterprises (AE) as referred to in section 77 of the

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Italy publishes new guidelines for TP documentation

28 November, 2020

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

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Singapore extends deadline for TP documentation

28 November, 2020

In response to the Covid-19 pandemic, for this group of companies which faced genuine difficulties in preparing and e-Filing the YA 2020 Corporate Income Tax (CIT) Returns due to the COVID-19 situation, the IRAS would grant them a 1-month extension

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