Belgium initiates TP audit cycle of 2021
In the week commencing 11 January 2021, a number of selected Belgian taxpayers received a transfer pricing (TP) questionnaires from the tax authority’s special TP audit department. The questionnaire consists of around 30 questions, which reflects
See MoreColombia increases the value of tax unit for 2021
On 11 December 2020, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales-DIAN) has issued Resolution No. 000111 in the official website. The Resolution increases the tax unit value (Unidad de Valor Tributario - UVT)
See MoreLuxembourg: Tax Authorities issues guidance on interest deduction limitation
On 8 January 2021, the Luxembourg Tax Authorities has published Circular L.I.R. n° 168bis/1 (French), which clarifies certain aspects of the interest expense deduction limitation rules included in article 168bis of the Luxembourg Income Tax
See MoreSpain publishes state budget bill for fiscal year 2021
On 31 December 2020, Spain’s State Budget Bill for Fiscal Year (FY) 2021 (the Budget Bill) was published in the Spanish Official Gazette after its prior approval by the Spanish Congress and Senate. The main corporate tax measures are summarized
See MoreKenya: President signs the Tax Law Amendment Act (No. 2) of 2020
On 23 December 2020, the President of Kenya signed the Tax Law Amendment Act (No. 2) of 2020 which amends the Income Tax Act and the Value Added Tax (VAT) Act of Kenya. Critical changes include reinstating corporation tax
See MoreRussia updates mandatory audit thresholds
On 29 December 2020, Russia has published Federal Law No 476-FZ which amended the thresholds for mandatory tax audit with effect from 1 January 2021. The Federal Law increased the turnover threshold in the previous year to RUB 800 million
See MoreIreland: President signs the Finance Bill 2020 into Law
On 19 December 2020, the President signed the Finance Bill 2020 into Law, which underpins the Government’s support for the economy in the face of Covid-19 pandemic and the ongoing threat of a no-deal Brexit. The Finance Act 2020 provisions
See MoreSingapore issues advance ruling summary on determination of related parties
On 4 January 2021, the tax Authority of Singapore has published Advance Ruling Summary No. 1/2021, regarding the determination of related parties for transfer pricing (TP) purposes in cases involving a joint venture without majority control.
See MoreSingapore updates indicative margins for related party loans
The Inland Revenue Authority of Singapore (IRAS) has published updated indicative margins for related party loans. IRAS has introduced an indicative margin which taxpayers can apply on each related party loan not exceeding S$15 million as tabulated
See MoreMorocco revises TP documentation penalty
On 18 December 2020, the Ministry of Finance of Morocco has published the Finance Law for 2021 in the Official Gazette, apply from 1 January 2021. Morocco's Finance Law 2021 introduced new transfer pricing (TP) documentation
See MoreBulgaria: Government reveals tax measures included in 2021 Budget
On 8 December 2020, the Government Officially published a Law, which provides tax measures included as part of the 2021 Budget. The key measures are given below: The Law introduced new deadline for filing annual corporate income tax returns up
See MoreArgentina: AFIP further extends the deadline for beneficial ownership declaration
On 31 December 2020, the Federal Administration of Public Revenue (AFIP) Officially published General Resolution 4897/2020 of 29 December 2020, which extends the initial reporting deadline of beneficial ownership declaration for 2019 and, with
See MoreGreece: MoF extends the deadline for beneficial ownership declaration
On 30 December 2020, a decision of the Deputy Minister of Finance, Mr. George Zavvos, was signed, which extends the deadline for the registration of beneficial ownership (UBO) information in the UBO registry from 31 December 2020 until 1 February
See MoreTransfer Pricing Brief: January 2021
AustraliaFinancial transactions-Restriction on interest deduction: 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
See MoreIreland: Finance Minister publishes a feedback on ATAD interest limitation rule
On 23 December 2020, the Finance Department published feedback statement, which considers the final ATAD measure, an Interest Limitation Rule, which will also be implemented in Finance Bill 2021. In Ireland, the general anti-abuse rule (GAAR) met
See MoreMalta: CFR releases guideline on DAC6 reporting
On 4 January 2021, the Maltese Commissioner for Revenue (CFR) has released guidelines concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) as per Council Directive (EU) 2018/822 of 25 May 2018. The guidelines
See MoreColombia issues a decree on the tax return and TP documentation deadline
On 17 December 2020, the Colombian Ministry of Finance and Public Credit has issued Decree 1680 specifying the deadlines for filing and payment of the tax return (declaration) in 2021 and the deadline for transfer pricing (TP) documentation,
See MoreSri Lanka: IRD publishes CbC reporting and notification due dates
On 22 December 2020, the Inland Revenue Department (IRD) of Sri Lanka has published a notice related to the filing of Country-by-Country (CbC) reports and notifications. According to the notice, the ultimate parent company or its
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