Italy: New circular clarifies application of ALP
On 24 May 2022, the tax authority of Italy has issued Circular No. 16/E, that clarifies the application of the arm's length principle (ALP) in transfer pricing as per Decree of 14 May 2018 and Decree No. 50 of 24 April 2017 as converted by Law No.
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India: CBDT updates guidance on MAP
On 10 June 2022, India's Central Board of Direct Taxes (CBDT) issued comprehensive updated guidance on the Mutual Agreement Procedure (MAP) and related matters. The guidance supplements the previous guidance published on 7 August 2020 and addresses
See MoreUkraine clarifies transfer pricing requirements under martial law
On 2 June 2022, the Ukrainian State Tax Service (STS) has published a notification that clarifies transfer pricing requirements under martial law conditions in Ukraine, taking into account of COVID-19 situation. Transfer pricing
See MoreOECD: New Transfer Pricing Country Profiles Published
On 9 June 2022 the OECD released new transfer pricing country profiles for Egypt, Liberia, Saudi Arabia and Sri Lanka. The OECD transfer pricing profiles cover the OECD member countries and a number of member countries of the Inclusive
See MoreDominican Republic: DGII invites comments on the draft MAP rule
On 26 May 2022, the Dominican Republic's Directorate General of Internal Revenue (DGII) launched a public consultation on a draft general standard (rules) on Mutual Agreement Procedures (MAP) for dispute resolution under the country's tax treaties.
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Netherlands publishes latest DAC6 reporting guidelines
The Netherlands Tax and Customs Administration have published latest user guidelines for the use of the Mandatory Disclosure/DAC6 data portal for reporting potentially aggressive cross-border tax arrangements. As a result of the Dutch
See MoreEstonia deposits new notifications under Article 35(7)(b) of the BEPS MLI
On 1 June 2022, the Organization for Economic Cooperation and Development (OECD) announced that the Republic of Estonia notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the
See MoreRomania: BEPS MLI in Force
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Romania on 1 June 2022. With regard to the tax treaties between Romania and other countries for which
See MorePoland: MoF reply to parliamentary inquiry on transfer pricing information
On 30 May 2022, the Treasury Department responded to a Parliamentary inquiry (No. 31287) regarding the rules for reporting certain transfer pricing information to be reported on the TPR-C form. According to response, the TPR-C form can be
See MoreSpain publishes form in relation to digital services tax
On 23 May 2022, Spain published the Order HFP/480/2022 approving a revised form 490 of “Digital Services Tax (DST)”. The form replaces the previous form approved in Order HAC/590/2021 of 9 June 2021 with effect for self-assessments corresponding
See MoreTransfer Pricing Brief: June 2022
ArgentinaFiling deadlines: On 28 April 2022, the Federal Public Revenue Administration (AFIP) published General Resolution 5189/2022 of 28 April 2022, which extends the submission deadline of corporate tax return to between 23 and 26 May 2022.See
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OECD: Report to G7 on Tax Cooperation for the 21st Century
On 20 May 2022 the OECD published a report on Tax Cooperation for the 21st Century. The German G7 Presidency requested the report from the OECD to examine further moves to strengthen international tax co-operation and make recommendations for
See MoreChina deposits BEPS MLI ratification instrument
On 25 May 2022, China has deposited its instrument of approval for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention). China's instrument of approval also covers Hong
See MoreBangladesh: NBR extends CIT return deadline
On 16 May 2022, the National Board of Revenue (NBR) of Bangladesh has published a Notice regarding the extension of the deadline for the filing of corporate income tax (CIT) returns for the 2020-2021 income year ended on 30 June 2021.
See MoreAustria publishes guidance on MAP procedures under DTAs, MLI, and EU Laws
On 6 May 2022, the Ministry of Finance issued new guidelines on mutual agreement and arbitration procedures (MAP) under the Austrian double taxation agreements, the EU Arbitration Convention, the BEPS Multilateral Instrument (MLI), and the EU Tax
See MoreCzech Republic: Supreme Court makes a decision of a TP case on related party transaction
Recently, the Supreme Administrative Court (SAC) held in judgment 7 Afs 398/2019 – 49 of a transfer pricing (TP) case that tax administrators may assess additional tax based on overall profitability not just for related-party transactions, but
See MoreLuxembourg: Tax Authorities updates guidance on DAC6
On 4 May 2022, the Luxembourg Tax Authorities has updated 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 guidance mainly covers
See MoreBelgium declares CIT return filing Deadline for tax year 2022
On 9 May 2022, the Federal Public Service Finance (SPF) of Belgium has issued a Notice declaring that the corporate income tax (CIT) return submission deadline is 17 October 2022 for the fiscal years ending from 31 December 2021 to 28
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