Italy updates filing instructions for CbC Report
The Italian tax authorities updated the technical rules and filing instructions to submit country-by-country (CbC) reports in accordance with the OECD’s CbC XML schema adopted in June 2019. The updated technical rules and filing instructions will
See MoreEgypt: President approves unified tax procedures law
On 19 October 2020, Egyptian President Abdel Fattah El Sisi has approved a unified tax procedures law (Law no. 206 of 2020). The Law was published in the Official Gazette. The law will be applied to tax on income, added value tax, stamp duty, fees
See MoreThailand declares penalty relief for transfer pricing disclosure forms in response to Covid-19 pandemic
The Revenue Department of Thailand declared a reduction of the penalty from THB 200,000 to THB 5,000 for late submissions of the transfer pricing (TP) disclosure form due to Covid-19 pandemic. The reduced penalty is available for disclosure
See MoreIsrael issues draft bill to amend transfer pricing documentation requirements
On 12 October 2020, the Israeli Tax Authority (ITA) published a draft bill for public consultation, proposing to amend Section 85A of the Income Tax Ordinance (ITO) and its regulations. The proposal incorporates the principles of the OECD’s
See MoreDenmark: High Court makes a decision against tax authority’s TP approach
On 5 October 2020, the High Court made a decision on a case entitled “Denmark vs. Shoe Group A/S” against the tax administration’s transfer pricing (TP) approach. The tax administration of Denmark used various theories to claim that a
See MoreBelgium: Further extension of deadline for CIT return and local file
On 12 October 2020, the Ministry of Finance declared further extension of the deadline for filing corporate income tax (CIT) return to 16 November 2020 for Assessment Year 2020. Previously, the corporate income tax returns filing deadline had been
See MoreZambia: MOF presents the budget for 2021 to the National Assembly
On 25 September 2020, the Minister of Finance (MOF) presented the budget for 2020 to the National Assembly. Under the budget the following important amendments to the Income Tax Act will take effect from 1 January 2021: Corporate tax
See MorePoland: Transfer pricing changes in recent tax law
On 29 September 2020, a draft bill amending the corporate income tax (CIT) laws was submitted to the lower house of the Polish parliament. The amendments include following proposals related to transfer pricing. Extends the application of the
See MorePeru extends country-by-country report submissions deadline
On 25 September 2020, the Peruvian tax authority has published Resolution No. 000155-2020/SUNAT, through which the country-by-country (CbC) reports on multinational group entities are extended for the fiscal year 2019. SUNAT extend it until the
See MoreHong Kong: IRD updates CbC XML schema and user guide
On 6 October 2020, Inland Revenue Department of Hong Kong has published the updated CbC reports XML schema and user guide. The Department has developed a data schema in XML which is based on the CbC XML Schema issued by the OECD. The data schema
See MorePoland: Parliament approves a bill to amend various income tax rules
On 30 September 2020, the Polish lower house of Parliament (Sejm) approved a Bill No.642 amending various income tax rules for business. The measures of Bill No. 642 will apply from 1 January 2021. The bill includes a number of proposed tax
See MoreOman introduces CbC Reporting requirements
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
See MoreTurkey publishes transfer pricing General Communiqué No. 4
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
See MoreCyprus: CbC reporting deadline is 31 December 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
See MoreHong Kong: IRD commence TP documentation compliance reviews
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
See MoreThailand reduces transfer pricing penalty amid Covid-19 pandemic
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
See MoreSingapore publishes transfer pricing guidance in response to the Covid-19 outbreak
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
See MoreBelgium: Transfer pricing deadlines for FY 2019
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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