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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UAE publishes new guidance on CbC reporting

25 November, 2020

On 2 November 2020, the Ministry of Finance of the United Arab Emirates (UAE) conducted a sessions on Cabinet Resolution No. 44 of 2020 with respect to the country-by-country (CbC) reporting requirements for multinational enterprise (MNE)

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Australia: ATO declares lodgment deferral for Local File, Master File, and CbC Report for FY 2019

18 November, 2020

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

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South Africa: SARS extends the CbC filing deadline

17 November, 2020

On 12 November 2020, the South African Revenue Service (SARS) published a notice, which stated that the due date for submitting country-by-country (CbC) report is extended on the basis of some specified person. According to the notice, the

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Belgium further extends Local file and CIT return filing deadline

15 November, 2020

On 12 November 2020, the Belgian Minister of Finance (MoF) announced a further extension of the filing corporate income tax (CIT) returns to 30 November 2020 for the Assessment Year 2020. Previously, the deadline for filing corporate income tax

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Vietnam: MoF issues new transfer pricing Decree

15 November, 2020

On 5 November 2020, the Vietnamese Ministry of Finance (MoF) has issued new transfer pricing Decree No. 132/2020/ND-CP. The new Decree replaces the existing Transfer Pricing (TP) regulations (Decree No. 20/2017/ND-CP) and provides the following new

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Ghana: Finance Minister submits new TP Regulations 2020 before Parliament

10 November, 2020

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,

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Lithuania publishes new transfer pricing requirements

04 November, 2020

On 19 October 2020, the Ministry of Finance in Lithuania published new transfer pricing documentation requirements. The new requirements for transfer pricing documentation correspond to the recommendations of OECD base erosion and profit shifting

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