Brazil: Government proposes new transfer pricing system
On 12 April 2022, the tax authority and Organisation for Economic Co-operation and Development (OECD) met to discuss Brazil’s proposal for a new transfer pricing (TP) system. The Brazilian Economy Minister, Paulo Guedes, said that the creation
See MoreBrazil and OECD present outline of new transfer pricing rules
On 12 April 2022 an event was held to present the outline of the new transfer pricing rules drafted by Brazil following a consultation process with the OECD. After Brazil had expressed the intention to become a full OECD member, Brazil and the
See MoreGreece: Government introduces new rules for interest deduction restriction
On 28 March 2022, Government published Law No. 4916/2022, which establishes new group escape rules for the 30% of EBITDA interest deduction restriction. The new group scape rule was made optional when the Greek interest restriction rules were
See MoreCyprus: Tax department publishes FAQs on DAC6 reporting
On 8 April 2022, the Tax Department of Cyprus has posted online Frequently Asked Questions (FAQs) regarding reportable cross-border tax arrangements (DAC6). The FAQs are currently available in Greek language and covered following
See MorePoland: MOF launches public consultations for TP method on resale price
On 4 April 2022, the Polish Ministry of Finance launched a public consultation on draft guidelines clarifying the resale pricing method for determining the arm's length value of transactions between associated parties. The guidance clarifies,
See MorePuerto Rico extends tax returns and payments deadlines for the tax year 2021
On 8 April 2022, the Puerto Rico Treasury Department (PRTD) issued Administrative Determination No. 22-03 extending the due date for income tax returns and tax payments for the tax year 2021. The PRTD determines to postpone the deadline to file
See MoreOECD: Strengthening Transfer Pricing Capacity in Mongolia
On 8 April 2022 the OECD published a tax and development case study entitled Tackling Multinational Tax Avoidance in Mongolia. In 2019 the OECD and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF)
See MoreTransfer Pricing Brief: April 2022
AngolaDocumentation-Requirement: On 15 March 2022, the Ministry of Finance of Angola has issued Order No. 1083/22 through which the list of the large taxpayers has been revised subject to the preparation of transfer pricing (TP) documentation.See
See MoreLuxembourg: Tax Authority updates guidance on interest deduction limitation
On 25 March 2022, the Luxembourg Tax Authority updated Circular L.I.R. n° 168bis/1 (French) which clarifies certain aspects of the interest expense deduction limitation rules included in article 168bis of the Luxembourg Income Tax Law (ITL).
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Ireland: Revenue issues an eBrief regarding DAC6
On 1 April 2022, the Revenue published an eBrief No. 078/22, which updates a manual regarding mandatory disclosure of reportable cross-border arrangements (DAC6). This was introduced by Finance Act 2021 and to provide additional guidance on the
See MorePeru modifies export & import transactions reporting requirements under TP rules
On 26 March 2022, Peru issued Legislative Decree No. 1537 in the official gazette regarding relaxing the term for the presentation of the communication of exported and imported goods and the obligation of the information to be registered in said
See MoreHong Kong: IRD issues profits tax, property tax and employer’s returns for 2021-22
The Inland Revenue Department today (April 1) issued about 220,000 profits tax returns, 120,000 property tax returns and 300,000 employer's returns for the year of assessment 2021-22. About 2.48 million tax returns for individuals will be issued on
See MorePoland: MOF extends the CIT return submission deadline for 2021
On 26 March 2022, the Polish Minister of Finance has signed an ordinance providing the extension of the deadline for the submission of corporate income tax returns for 2021. The deadline for the submission of corporate tax returns and the payment
See MoreThailand deposits BEPS MLI ratification instrument
On 31 March 2022, Thailand has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Convention or MLI), which now covers over 1800 bilateral
See MoreUS: Treasury Department releases tax proposals from Budget 2023
On 28 March 2022, the Treasury Department of United States published details of tax proposals in the administration’s budget recommendations for FY 2023 in the “GreenBook.” The Greenbook describes following tax measures related to corporate
See MoreThailand extends transfer pricing disclosure deadline
On 25 March 2022, in response to the COVID-19 pandemic, the Thai Minister of Finance has announced an extension the deadline for filing the transfer pricing disclosure form to 30 May 2022 for the fiscal years starting on or after 1 January 2020 to
See MoreRussia raises the threshold for controlled transactions
On 22 March 2022, the Russian Parliament amended the criteria for controlled transactions for transfer pricing purposes. Accordingly, the general transaction threshold for transactions to be considered controlled transactions will be raised from
See MorePoland: MOF extends the deadline for APA implementation report
On 23 March 2022, the Polish Ministry of Finance has published a press release extending the deadline for APA implementation report to 30 June 2022. The deadline extension applies to companies with financial years ending between 1 December 2021 and
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