Australia: ATO releases final guidance on related party loan
On 10 December 2020, the Australian Taxation Office (ATO) issued final transfer pricing guidance on interest-free loans between related parties, in “Schedule 3 – Interest-free loans” to the ATO’s financing Practical Compliance Guideline
See MorePoland publishes law amending corporate income tax act
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
See MoreAustralia updates APA guidance
On 3 December 2020, the Australian Taxation Office (ATO) published an updated law administration practice statement about the advance pricing arrangements (APA) program. The updated guidance (PS LA 2015/4) reflects changes to the APA
See MoreDenmark: Parliament adopts a Law regarding transfer pricing
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
See MoreGermany publishes a law for the ratification of BEPS MLI
On 27 November 2020, Germany published the law in the Official Gazette to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Germany must now deposit its ratification
See MoreFinland: Tax authority publishes CbC reporting XML schema version 2.0
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
See MoreSri Lanka: IRD postpones Master file and CbC reporting requirements
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
See MoreIreland: Revenue updates CbC user guide
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
See MoreMexico issues general tax rules on Mandatory Disclosure Rules (MDR)
On 18 November 2020, the Mexican Tax Administration (SAT) has issued general tax rules (GTR) for 2020. The GTR includes a new ‘chapter’ related to the mandatory reporting requirements for certain transactions. Mandatory Disclosure Rules (MDR)
See MoreMalta: CFR updates CRS and CbC XML schema and user guide
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
See MoreCanada: Finance Department introduces new GST/HST requirement for new DST
On 30 November 2020, the Finance Department published the Fall Economic Statement 2020 - Supporting Canadians and Fighting COVID-19, including prudent fiscal plan with proposed measures for a tax system for the digital economy. Under current rules,
See MorePeru: Tax Administration issues report on interest deduction limitations
On 10 November 2020, the Peruvian Tax Administration (SUNAT) has published Report No. 093-2020-SUNAT/7T0000 on its website, which clarifies the interest deduction limitations rules. Through the Report, SUNAT analyzes the application of the
See MorePeru: SUNAT extends CbC reports submissions deadline for FY 2017, 2018 and 2019
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
See MoreSri Lanka: TP documentation requirement for domestic controlled transactions
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
See MoreArgentina: AFIP extends suspension on inspections, assessments, appeals
In response to corona virus pandemic, on 27 November 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4868/2020 of 27 November 2020, providing an extension of suspension up to 31 December 2020 regarding
See MoreTransfer Pricing Brief: December 2020
AustraliaCbC reporting requirement/Master File/Local File: The Australian Taxation Office (ATO) has issued a notice declaring a lodgment deferral until 29th January 2021 for the Local file, Master file, and Country-by-Country (CbC) report for the
See MoreIndonesia notifies the confirmation of the completion of its internal procedures for MLI
On 26 November 2020, the Republic of Indonesia deposited a notification confirming the completion of its internal procedures for the entry into effect of the provisions of BEPS MLI. Indonesia signed the agreement on 7 June 2017 and it became
See MoreKazakhstan deposits notifications on its tax agreements
On 27 November 2020, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, on 26 November
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