Israel: New Tax Circular on burden of proof related to TP audits
On 2 June 2020, the Israeli Tax Authority (ITA) published tax circular 1/2020 addressing the situations in which a transfer pricing (TP) study that is filed by a taxpayer will be considered as meeting the Israeli TP standards in accordance with
See MoreArgentina: AFIP extends the transfer pricing documentation deadlines
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 previous starting due dates of June declared in
See MoreFrance: Tax authorities extend annual transfer pricing return up to 31 December 2020
On 10 June 2020, the Tax authority updated questions and answers regarding coronavirus outbreak and announced that the deadline for the annual transfer pricing return for companies whose fiscal year closed on 31 December 2019 is extended from 31
See MoreSweden: Parliament approved Law implementing DAC6
On 4 June 2020, the Swedish parliament has approved Law implementing the Council Directive (EU) 2018/822 (commonly known as DAC6) which introduces disclosure obligations for intermediaries and taxpayers of certain reportable cross-border
See MoreSaudi Arabia: GAZT releases the second edition of transfer pricing guidelines
In May 2020, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia has released the second edition of Transfer Pricing Guidelines (translated version). The Guidelines includes most of the section of the first edition, which was released in
See MoreNetherlands publishes guidance on mandatory disclosure Rules/DAC6
The Dutch Tax Authority has published an English-language version of its general guidance on Mandatory Disclosure Rules/DAC6. The European Directive Mandatory Disclosure Rules (MDR)/DAC6 will come into effect on 1 January 2021. As a result of
See MoreAustralia updates guidelines for resolving international tax disputes
The Australian Taxation Office (ATO) has updated the guidelines for the mutual agreement procedure (MAP) and arbitration arrangements. The updated guidelines reflect modifications made (or to be made) in some of Australia’s tax treaties made
See MorePhilippines: House of Representatives introduces a Bill regarding digital economy
On 19 May 2020, the Philippine House of Representatives introduced House Bill No. 6765 regarding an establishment of fiscal regime for the digital economy. The Bill includes digital advertising services, electronic commerce platform, network
See MorePeru: SUNAT modifies tax filing deadline again amid COVID-19 pandemic
On 29 May 2020, the Peruvian tax authorities (SUNAT) issued Resolution No. 099-2020/SUNAT in the Official Gazette modifying previous Resolution No. 055-2020/SUNAT and 065-2020/SUNAT in response to COVID-19 pandemic. The Resolution further extends
See MoreCzech Republic: Finance Ministry announces liberation package III due to COVID-19 pandemic
On 9 June 2020, the Ministry of Finance announced on its website that the so-called next liberation package III has been approved to extend and extend certain tax exemptions, tax accessories and administrative fees due to an emergency caused by
See MoreSouth Korea deposits MLI ratification instrument
On 13 May 2020, South Korea deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI will enter into force for South Korea on 1
See MoreLuxembourg: MOF extends deadlines for DAC6 reporting amid COVID-19
On 4 June 2020, the Luxembourg Ministry of Finance (MOF) has published a statement extending the reporting deadline of EU directive on reporting requirements for certain cross-border transactions (DAC6) amid COVID-19 pandemic. On 3 June 2020, EU
See MoreCanada: The CRA extends tax return deadline until 1 September 2020
On 1 June 2020, the Canada Revenue Agency (CRA) published updated information on their website regarding the extension of corporate tax return or information return submission deadline for businesses, trusts, or partnerships until 1 September 2020
See MoreTurkey: Parliament considers bill to ratify BEPS Multilateral Instrument (MLI)
On 2 June 2020, a draft ratification law has been submitted to the Turkish Parliament for the ratification of the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI). The following day,
See MoreUkraine: President signs law to implement BEPS and other provisions
On 21 May 2020, the President of Ukraine signed Law No. 466-IX (Draft Law No.1210) “On Amendments to the Tax Code of Ukraine on Improvement of Tax Administration, Elimination of Technical and Logical Inconsistencies in Tax Legislation", which was
See MoreTransfer Pricing Brief: June 2020
ArgentinaScope of transfer pricing rules: On 15 May 2020, the Argentine tax authorities (AFIP) officially published General Resolution 4717/2020 of 14 May 2020, which governs the control of transfer prices of international transactions. The new
See MoreCzech Republic: Finance Minister announces to delay the DST with a reduced rate
On 14 May 2020, the Finance Minister announced in a televised interview that the Government agreed to reduce the digital service tax (DST) from 7% to 5%. Also, the Government agreed to postpone the introduction of DST until 1 January 2021. The
See MoreSri Lanka: Extended deadline of transfer pricing disclosure form for YA 2018/2019
On 29 May 2020, according to notice PN/Tax Return/2020-3, the Sri Lankan Inland Revenue Department has again extended the deadline for the transfer pricing disclosure form for Year of Assessment 2018/2019 to 30 June 2020. The deadline was
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