Dominican 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
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 MoreJordan issues Executive Instructions on new TP rules for MNE groups
On 16 September 2021, the Hashemite Kingdom of Jordan has published Executive Instructions No. 3 of 2021 regarding new transfer pricing (TP) rules for MNE groups. Jordan has published Regulation No. 40 of 2021 On 7 June 2021 which introduces
See MoreItaly launches public consultation on draft circular on TP documentation requirements
The Italian tax authorities have introduced a public consultation on the draft circular clarifying transfer pricing (TP) documentation requirements. Comments should be submitted by 12th October 2021 to the email
See MorePeru sets CbC reports ‘secondary filing’ for US parent entities located in Peru
There is no automatic exchange of country-by-country (CbC) reports agreement between Peru and the United States (US). So the US parent entities located in Peru will be required secondary filing by mid-October 2021 for the fiscal year 2020. The
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 №
See MoreMexico: Executive Branch submits 2022 economic proposal to Congress
On 8 September 2021, the Mexican Executive Branch has submitted Economic Package for the fiscal year 2022 including a proposal of Tax Reform. The proposed 2022 Tax Law clarifies income tax law, value-added tax (VAT) law, excise tax (duty)
See MoreMalaysia: IRBM releases updated FAQs providing new CbCR submission requirement
On 13 September 2021, the Inland Revenue Board of Malaysia (IRBM) has published the updated “frequently asked questions on tax matters during the national recovery plan”. Accordingly, companies in Malaysia responsible for filing the CbCR report
See MoreBotswana: General Commissioner sets TP documentation threshold
On 1 September 2021, the General Commissioner published a ruling and set a threshold for the preparation and submission of transfer pricing documentation. The ruling is effective retroactively from 1 July 2019 (2020 tax year). According to the
See MoreIndia extends the due dates for E-filing of various forms
On 29 August 2021, the CBDT published circular No. 16/2021 to extend the deadlines for the electronic submission (E-filing) of various forms. Accordingly, the due date for filing the CbC report notice (i.e. Form 3CEAC) may be submitted on or before
See MoreNigeria: FIRS suspends CbC report local filing for non-parent entities
In September 2013, the Organization for Economic Co-operation and Development (OECD) and G20 countries, working together on an equal footing, adopted an ambitious and comprehensive 15-point Action Plan to address BEPS. The Action Plan aims to
See MoreGermany updates the CbC Reporting requirements based on the Annual Tax Act 2020
The Federal Ministry of Finance recently published a notice on the current issue of the Federal Central Tax Office's newsletter, which updates the country-specific (CbC) reporting requirements due to the 2020 Annual Tax Act. As a result of the
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 MoreDominican Republic: DGII invites for public comments regarding CbC reporting requirements
Recently, the Directorate General of Internal Revenue (DGII) declared a public consultation on a draft general standard regarding country-by-country (CbC) reporting. The DGII invited for public comments up to 7 September 2021. The CbC report
See MoreLuxembourg updates electronic exchange and frequently asked questions of CbC report
On 20 August 2021, Luxembourg has announced that the section "Electronic exchange - country by country (CbC) reporting" as well as the frequently asked questions relating to the CbC declaration have been updated. Please note that the frequently
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