Ecuador: The Internal Income Service amends prior Resolutions regarding transfer pricing
On 1 July 2020, the Government published Resolution No. NAC-DGERCGC20-00000046 of 1 July 2020, which amends the calculation of profit level indicators. According to amendments, it is provided that taxpayers must use the last financial information
See MoreCOVID-19: India further extends the deadlines of tax returns
On 24 June 2020, the Central Board of Direct Taxes of India has published a Notification No 35/2020 of 24 June 2020 providing the following extension of time limits under the Income Tax Act and related Acts due to COVID-19. The time for filing
See MoreLatvia defers the first mandatory disclosure rules (DAC 6) reporting deadlines
On 29 June 2020, Latvian Ministry of Finance has announced that the first reporting deadlines of cross-border arrangements (DAC6) provided by Council Directive (EU) 2020/876 will be deferred by six months in order to provide taxpayers and
See MoreEstonia extends deadlines for DAC6 reporting amid COVID-19
On 26 June 2020, the Estonian Ministry of Finance has proposed for the deferral of reporting on EU cross-border arrangements (DAC6) due to COVID-19 pandemic. All reporting and data exchange deadlines in 2020, the first reporting year, are thus
See MoreCyprus Gazettes EU Anti-Tax Avoidance Directive
After the partial adoption of the EU Anti-Tax Avoidance Directive (ATAD I) of 12 July 2016 in 2019, on 19 June 2020 the Parliament of Cyprus voted into law the remaining provisions of ATAD I, as well as the provisions of the EU ATAD II of
See MoreTransfer Pricing Brief: July 2020
ArgentinaTransfer pricing information return: On 5 June 2020, the Federal Administration of Public Revenue (AFIP) Officially published a General Resolution No. 4733 of 4 June 2020 to file affidavits under transfer pricing rules and postpones the
See MoreMalta extends deadlines for DAC6 reporting amid COVID-19
On 2 July 2020, the Maltese Commissioner for Revenue has announced the deferral of reporting on EU cross-border arrangements (DAC6) due to COVID-19 pandemic. All reporting and data exchange deadlines in 2020, the first reporting year, are thus
See MoreSlovenia extends deadlines for DAC6 reporting amid COVID-19
On 30 June 2020, the Slovenian Financial Administration published a statement regarding deferral of reporting on EU cross-border arrangements (DAC6) due to COVID-19 pandemic. All reporting and data exchange deadlines in 2020, the first
See MoreDenmark: Tax authority extends the initial DAC6 reporting by six months
On 29 June 2020, the Tax authority updated guidance to announce that the primary deadline of reporting cross-border arrangements (DAC6) are extended by six-months. The specific deadlines are declared through an Executive Order (BEK) No. 1049 of 29
See MoreArgentina: AFIP extends the deadline of audited financial statements
On 26 June 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4743/2020 of 25 June 2020, which states that due to coronavirus pandemic, the submission deadline of audited financial statements or auditor's report
See MoreOECD: Meeting of the Inclusive Framework on BEPS
On 1 July 2020 the OECD Secretary General delivered the opening address for the July 2020 meeting of the Inclusive Framework on base erosion and profit shifting (BEPS). The countries involved in the Inclusive Framework are working towards
See MorePoland: Ministry of Finance further extends TP documentation deadline due to COVID 19
On 24 June 2020, the Polish Ministry of Finance announced the further extension of transfer pricing documentation deadlines due to the coronavirus pandemic. The announcement extends the local transfer pricing documentation preparation deadline as
See MoreDenmark: Supreme Court makes a decision regarding royalties and TP documentation
On 25 June 2020, the Supreme Court made a decision on a case, entitled “Denmark vs. Adecco A/S”, in favor of Danish company, Adecco, and its Swiss parent company in a dispute involving the deductibility of royalties and the sufficiency of
See MoreKazakhstan deposits MLI ratification instrument
On 24 June 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, Kazakhstan on 24
See MoreIreland: Tax authority extends the DAC6 reporting timelines by six months
Due to coronavirus outbreak, the European Commission has recently agreed to delay the entry into force of certain European Union (EU) taxation measures. Among these is the delay of Council Directive 2018/822, commonly known as the Directive on
See MoreSweden: Tax Agency extends deadlines for DAC6 reporting amid COVID-19
On 24 June 2020, the Swedish Ministry of Finance published a statement announcing its intension to extend the reporting deadline of EU directive on reporting requirements for certain cross-border transactions (DAC6) due to the outbreak of the
See MoreCzech Republic: Financial Administration announces to expect a delay on DAC6 implementation
Amid COVID-19 pandemic, and in response to requests from European trade associations, the European Commission has published its proposal to amend Directive 2011/16/EU which deals with various strands of administrative co-operation in the field of
See MoreBelgium declares guidelines on EU directive DAC6
On 26 June 2020, the Belgian tax authorities published a circular on the EU directive on mandatory disclosure of cross-border arrangements (DAC6) with effective from 1 July 2020. The published circular provides guidelines on the interpretation
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