Malta seeks comments on draft Transfer Pricing Rules
On 22 December 2021, Malta’s Commissioner for Revenue (CFR) has published draft Transfer Pricing Rules on its website for public consultation. The consultation period will end on 28 February 2022, and the draft Transfer Pricing Rules shall come
See MoreIceland sets 31 January 2022 deadline for 2021 CbC notification
On 22 December 2021, Iceland published the Notice No.1490/2021 which provides that the CbC report notification in respect of the 2021 fiscal year is to be submitted by 31 January 2022. Companies must designate a company group member to submit CbC
See MoreFinland issues guidance on application of OECD guidelines for domestic TP rules
On 17 December 2021, the Finnish Tax Administration issued Guidance No. VH/5755/00.01.00/2021, on the application of OECD transfer pricing guidelines to domestic transfer pricing rules, effective from 31 December 2021. On 11 February 2020, the
See MoreIreland: Government seeks Public Consultation on CbC tax reporting
On 20 December 2021, the Department of Enterprise, Trade and Employment is seeking the views of stakeholders through a Consultation on the transposition of the new EU directive requiring public country-by-country (CbC) reporting of income tax
See MoreOECD: Updates to Transfer Pricing Country Profiles
On 13 December 2021 the OECD released updated transfer pricing country profiles for 18 countries, together with new transfer pricing profiles for Albania, Kenya and the Maldives. The OECD has now created transfer pricing profiles for a total of 63
See MoreCyprus: Tax department extends the deadline for submitting local CbCR reporting
On 20 December 2021, the Cyprus Tax Department published an announcement informing that the deadline for submission for local CbCR reporting due to the secondary filing mechanism (including Equivalent reporting) for the year 2020 is the 31st of
See MoreThailand revises CbC reporting deadline
On 23 December 2021, the Thai Revenue Department has published a notification on amendments to the filing deadlines for Country-by-Country (CbC) reports. Previously CbC report filing deadline was as same as the annual tax return deadline,
See MoreIreland: Revenue updates guidelines for requesting MAP assistance
On 23 December 2021, the Revenue published an eBrief No. 236/21 on the updated Manual for requesting Mutual Agreement Procedure (“MAP”) assistance in Ireland. The Guide has been updated to incorporate Council Directive (EU) 2017/1852 of 10
See MoreOECD: Peer Review Report on Harmful Tax Practices
On 14 December 2021 the OECD published a report entitled: Harmful Tax Practices – 2020 Peer Review Reports on the Exchange of Information on Tax Rulings. The standard under Action 5 of the OECD/G20 action plan on base erosion and profit
See MoreFrance: Tax Authority publishes a guide regarding the application of anti-hybrid rules
On 15 December 2021, the Tax Authority published a guide, which covers the measures implemented in compliance with the EU Anti-Tax Avoidance Directive as amended (ATAD1 and ATAD2) as part of the Finance Law for 2020. The hybrid mismatch measures
See MoreSouth Africa: SARS opens a public consultation for an APA program
On 10 December 2021, the South African Revenue Service (SARS) made an announcement for inviting public comments for a model and draft legislation regarding Advance Pricing Agreement (APA) system until the end of January 2022. The draft model is
See MoreAustralia: ATO issued PCG 2021/5 on imported hybrid mismatch rule
On 16 December 2021, the Australian Taxation Office (ATO) issued Practical Compliance Guideline 2021/5 on imported hybrid mismatch rule – ATO’s compliance approach (PCG 2021/5) relating to a practical administrative approach to the imported
See MoreLuxembourg updates the list of jurisdictions for exchanging CbC reports
On 13 December 2021, the Luxembourg Ministry of Finance published Grand-Ducal Regulation of 9 December 2021 in the Official Gazette amending Grand-Ducal Regulation of 13 February 2018. The Regulation updates the list of
See MoreFinland: Parliament adopts the law on transfer pricing adjustment
On 9 December 2021, the Finnish Parliament has approved the amendment to the transfer pricing adjustment provision, (VML Section 31) of the Tax Procedure Act (VML). On 16 December 2021, the President signed the law, the amendment will take effect
See MorePanama amends CbC reporting penalties
On 11 November 2021, Panama published Law No. 254 in the Official Gazette No. 29413-A, which amends the legislation on international tax transparency and the prevention of money laundering, and the financing of terrorism. The significant
See MoreUK: Compliance Experience of Large Business
On 30 November 2021 the UK government published its response to the review of large businesses’ experiences of UK tax administration, taking into account the feedback received from stakeholders. The review, first announced in the Spring Budget
See MorePortugal publishes new transfer pricing Legislation
On 26 November 2021, the Portuguese Tax Administration (PTA) published Order No. 268/2021, which replaces Regulation No. 1446-C / 2001 of December 21, 2001. The new regulation revises the rules for implementing the arm's length principle under
See MoreZambia proposes transfer pricing changes
On 29 October 2021, the Zambian government has presented the budget for 2022 to the Parliament. The budget proposes a number of significant changes in corporate taxation including amendments to transfer pricing regulations. The budget introduces
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