Oman introduces CbC Reporting requirements

29 September, 2020

On 27 September 2020, Oman published Ministerial Decision No. 79/2020 in the Official Gazette announcing the introduction of Country-by-Country (CbC) reporting and notification requirements for multinational entity groups (MNE groups) headquartered

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Turkey publishes transfer pricing General Communiqué No. 4

24 September, 2020

On 1 September 2020, the Turkish Revenue Administration has published transfer pricing General Communiqué No. 4 on disguised profit distribution in the Official Gazette No. 31231. The Communiqué explains information regarding new transfer pricing

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Cyprus: CbC reporting deadline is 31 December 2020

23 September, 2020

The deadline for multinational enterprise (MNE) groups to comply with the country-by-country (CbC) reporting and notification obligations in Cyprus is 31 December 2020 for the fiscal year 2019. CbC reports and notifications are submitted through

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Hong Kong: IRD commence TP documentation compliance reviews

23 September, 2020

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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Thailand reduces transfer pricing penalty amid Covid-19 pandemic

15 September, 2020

On 9 September 2020, the Revenue Department of Thailand announced to reduce fine for the late submission of the annual transfer pricing disclosure from THB 200,000 to THB 5,000 due to the Covid-19 pandemic, provided that the transfer pricing

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Singapore publishes transfer pricing guidance in response to the Covid-19 outbreak

13 September, 2020

On 8 September 2020, the Inland Revenue Authority of Singapore updated its website by including guidance regarding transfer pricing in response to the Covid-19 pandemic. The guidance is provided in a following question and answering

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Belgium: Transfer pricing deadlines for FY 2019

10 September, 2020

The Belgian taxpayers should be aware of the transfer pricing documentation requirements and the applicable deadlines to comply with the requirements. The taxpayers have an obligation to prepare and file the following transfer pricing forms if

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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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Hong Kong and Russia sign an agreement for the exchange of CbC report

09 September, 2020

On 3 September 2020, the Russian Federal Tax Service has announced that Hong Kong and Russia signed an agreement on the exchange of Country-by-Country (CbC) reports for the 2017 and 2018 reporting years. For reporting fiscal years beginning on or

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Poland clarifies the treatment of dividends under TP rules

04 September, 2020

On 6 August 2020, the Polish Ministry of Finance has issued a guidance on whether a dividend payment among related entities falls within the scope of the definition of a “controlled transaction” for transfer pricing purposes. The uncertainty

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New Zealand: Inland Revenue releases guidance on transfer pricing amid COVID-19

31 August, 2020

Recently, New Zealand’s Inland (IR) Revenue has released guidance regarding practice issues for transfer pricing due to the COVID-19 pandemic. The COVID-19 pandemic has created an impact on specific sectors and businesses substantially. 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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Greece: Parliament published two Laws to introduce various changes in transfer pricing context

12 August, 2020

On 31 July 2020 and on 29 July 2020, the Greek Parliament Officially published two Laws, L. 4714/2020 and L. 4712/2020 respectively regarding various sections of transfer pricing. The two Laws cover the following changes: Tax dispute Resolution

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Tanzania: Revenue Authority issues new transfer pricing guideline 2020

30 July, 2020

On 1 July 2020, the Tanzania Revenue Tax Authority issued the Transfer Pricing Guidelines 2020, which provides the instructions of how to apply Transfer Pricing Regulations, 2018. It covers the guidance on the arm’s length principle, functional

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Oman anticipates amending Transfer Pricing and VAT regime

29 July, 2020

It is being announced that the Council of Ministers of Oman has referred two draft laws to the Shura Council related to VAT regime and amendments to the income tax law that would implement country-by-country (CbC) reporting. Oman is intended to

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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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