Argentina: AFIP modifies transfer pricing local compliance obligations
On 10 June 2019, the Federal Administration of Public Revenues (AFIP) published General Resolution No. 4502 in the official gazette amending transfer pricing local compliance obligations. The resolution overruled some information including
See MoreNigeria: TP returns due on 30 June
It’s a reminder for the companies with a 31 December year-end required to file a transfer pricing (TP) return by 30 June 2019. Pursuant to the Transfer Pricing Regulations of 2018, existing companies with financial year-end of 31 December 2018
See MorePanama implements CbC reporting requirements
On 27 May 2019, the Ministry of Economy and Finance of Panama published Executive Decree No. 46 in the official gazette. The decree was issued regarding implementation of country-by-country (CbC) reporting with following
See MorePanama updates form for related-party transactions
In Panama, an information return (Form 930) on the transactions conducted with related parties resident abroad should be filed within six months of the close of the fiscal year. The taxpayers, whose transactions with related parties that took place
See MoreSaudi Arabia: Cabinet approves multilateral competent authority agreement on the exchange of CbC reports
On 28 May 2019, the Saudi Arabian Cabinet sanctioned the signature of the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA). Saudi Arabia presented CbC reporting requirements, including standard
See MoreArgentina modifies TP documentation requirements
On 27 May 2019, the Federal Administration of Public Revenue (AFIP) has published General Resolution 4496 (GR 4496) in the official gazette amending General Resolution 1122 (GR 1122). The resolution explains requirements, deadline, thresholds for
See MoreBulgaria: Parliament adopts amendments to TP documentation bill at first-reading
On 5 June 2019, the Bulgarian Parliament adopted at first reading amendments to the Tax and Insurance Procedure Code, which introduced the new transfer pricing (TP) documentation requirements. One of the most important changes is in relation to
See MoreTransfer Pricing Brief: June 2019
HungaryDocumentation-Timing: On 8 May 2019, the Hungarian National Tax and Customs Administration issued a notice to remind taxpayers that they must prepare their transfer pricing documentation by 31 May 2019 if they are required to keep
See MoreNew Zealand: Inland Revenue publishes revised transfer pricing regime
On 29 April 2019, Inland Revenue published the final versions of the special reports on the new rules for base erosion and profit shifting (BEPS). The rules were enacted in the Taxation (Neutralising Base Erosion and Profit Shifting) Act 2018 on 27
See MorePhilippines: DOF submits tax reform bill to Congress
The Philippines Department of Finance (DOF) has announced on 25 April 2019 that the second package (Tax Reform for Attracting Better and High-Quality Opportunities or TRABAHO) of the Duterte administration’s Comprehensive Tax Reform Program
See MorePoland publishes law amending CbC reporting rules
On 15 April 2019, Poland published the Act of 4 April 2019 amending the Act on the exchange of tax information with other countries and certain other acts including Country-by-Country (CbC) reporting rules. Under this, if a group prepares its
See MoreBelgium Updates XML Tool and the XSD schema for Local File
The Belgian Federal Public Service (SPF) Finance has published an update version 2.1 of the XML tool and the XSD schema for the Transfer Pricing (TP) Local file (Form 275 LF), which must be used for Local files submitted via the MyMinfin platform
See MoreIndonesia: MoF publishes new guidance on MAP
On 26 April 2019, the Minister of Finance (MoF) issued a new provision on the Mutual Agreement Procedure (MAP) with Regulation No. 49 / PMK.03 / 2019 (PMK-49). PMK-49 is effective from 26 April 2019 and repeals MoF Regulation No. 240 / PMK.03 /
See MoreGreece transposes the rules of the EU Anti-Tax Avoidance Directive
On 24 April 2019, Greece published Law 4607/2019 in the Official Journal containing measures to implement certain aspects of the EU's Tax Avoidance Directive (ATAD). This includes the replacement of existing rules to bring them in line with ATAD.
See MoreIndia: CBDT signs 18 new APAs
On 3 April 2019, the Central Board of Direct Taxes (CBDT) has announced the signing of 18 advance pricing agreements (APAs) during March 2019, including three bilateral APAs. With the signing of these APAs, the total number of APAs entered into
See MorePeru: SUNAT issues a new transfer pricing guideline on related-party share transfers
On 16 May 2019, Peruvian tax administration published a guidance “Informe No. 057-2019-SUNAT/7T0000” outlining the tax treatment of transfers of undervalued Peruvian entity shares involving foreign related parties. Under this any transfer
See MoreAustria: MoF proposes draft legislation regarding tax reform for 2019-2020
On 8 May 2019, the Austrian Ministry of Finance published a draft bill regarding tax reform for 2019-2020. The main measures of the draft bill are following: -A reduction in the corporate tax rate from 25% to 23% in 2022 and to 21% in
See MoreHungary: NTC publishes a notice to remind taxpayers for deadline of TPD
On 8 May 2019, the Hungarian National Tax and Customs Administration issued a notice to remind taxpayers that they must prepare their transfer pricing documentation by 31 May 2019 if they are required to keep transfer pricing records and closed
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