Denmark: 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
See MoreChile: SII publishes new transfer pricing reporting obligations
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
See MoreHong Kong and Russia sign an agreement for the exchange of CbC report
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
See MorePoland clarifies the treatment of dividends under TP rules
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
See MoreNew Zealand: Inland Revenue releases guidance on transfer pricing amid COVID-19
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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