Transfer Pricing Brief: October 2022
Armenia Compliance with BEPS standards: On 14 September 2022, the Armenian Parliament (National Assembly) approved draft Bill No. K-294 for ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
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Puerto Rico extends tax returns and payment deadline due to Hurricane Fiona
On 27 September 2022, the Puerto Rico Treasury Department (PRTD) issued Administrative Determination No. 22-08 extending the due date for income tax returns and tax payments due to Hurricane Fiona. The PRTD extends the tax returns deadline until
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South Africa deposits ratification instrument for MLI
On 30 September 2022, South Africa deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI will come into effect for
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Belgium declares deadline for filing Local file forms
Belgian tax authority has declared the deadline for filing Local file forms (275LF) is 17 October 2022. The submission of a Local file is required for Belgian companies and permanent establishments (PEs) that meet at least one of three
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Ireland: Revenue updates guide to exchange of information under DAC6
On 26 September 2022, the Irish Revenue published an eBrief No. 175/22 on Guide to Exchange of Information. Accordingly. Tax and Duty Manual Part 35-01-01a (the Guide) under Council Directive 2011/16/EU, Ireland’s double taxation agreements and
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Greece amends corresponding adjustment provisions for Transfer Pricing
On 23 September 2022, Greece published Law No. 4972/2022 in the Official Gazette containing various tax measures including transfer pricing. The law amends an existing provision on transfer pricing adjustments upwards to provide for corresponding
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Armenia: Parliament approves a bill to ratify BEPS MLI
On 14 September 2022, the Armenian Parliament (National Assembly) approved draft Bill No. K-294 for ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). On 7 June 2017, Armenia signed the agreement
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Hong Kong: BEPS MLI enters into force
On 16 September 2022, OECD has published the update list of signatories and parties to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, MLI entered into force for
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Switzerland suspends tax information exchange arrangement with Russia
On 22 September 2022, the State Secretariat for International Finance (SIF) of Switzerland published a notification declaring the suspension of exchange of tax information with Russia. The temporary suspension applies to all types of tax information
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Bulgaria Deposits Instrument of Ratification for MLI
On 16 September 2022, Bulgaria deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI). The Convention will enter into force in relation to Bulgaria on 1
See MoreUkraine clarifies procedures for completing report on controlled transaction
On 19 September 2022, the State Tax Service (STS) of Ukraine clarified the procedure for filling and completeness of submission of report on controlled transactions. STS reminds that in accordance with requirements of Article 39 of the Tax Code,
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Poland releases ordinance on transfer pricing information
On 13 September 2022, the Polish Official Gazette released Ordinance Nos. 1923 and 1934, clarifying transfer pricing information in the scope of personal and corporate income tax. The ordinances include the following tax measures: Defining the
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Turkey approves effective date on CAA regarding CbC exchange arrangement with US
On 13 September 2022, the Turkish Revenue Administration issued Presidential Decision No. 6033 in the Official Gazette, through which Turkey has approved the effective date of the Competent Authority Agreement (CAA) to exchange country-by-country
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Dominican Republic: DGII Publishes general standard rule on MAP
On 30 August 2022, the Dominican Tax Authorities (DGII) issued a new general standard rule on Mutual Agreement Procedures (MAP) for Dispute Resolution under the country's tax treaties. The general rules introduced details for submitting MAP
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OECD: Peer Review Report on Dispute Resolution Mechanisms in Vietnam
The second stage peer review report on the implementation of the Action 14 minimum standard (making dispute resolution more effective) in Vietnam was published by the OECD’s Inclusive Framework on 13 September 2022. The report notes that
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OECD: Peer Review Report on Dispute Resolution Mechanisms in Bahrain
The second stage peer review report on the implementation of the Action 14 minimum standard (making dispute resolution mechanisms more effective) by Bahrain was published by the OECD’s Inclusive Framework on 13 September 2022. The report notes
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OECD: Peer Review Report on Dispute Resolution Mechanisms in Qatar
The second stage peer review report on the implementation of the Action 14 minimum standard (making dispute resolution mechanisms more effective) by Qatar was published by the OECD’s Inclusive Framework on 13 September 2022. The report notes
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OECD: Peer Review Report on Dispute Resolution Mechanisms in Oman
The second stage peer review report on Oman’s implementation of the minimum standard under BEPS Action 14 (making dispute resolution mechanisms more effective) was published by the OECD’s Inclusive Framework on 13 September 2022. The report
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