Cyprus: 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
See MoreSpain: Tax authority publishes a guide and Q&As on MAP
On 19 November 2021, the tax authorities have issued a guide and questions and answers (Q&As) on mutual agreement procedures (MAPs) to provide taxpayers with guidance on the main aspects of MAP. The Q&As clarified that the Spanish
See MoreUS: Tax Court refuses for reconsideration in transfer pricing dispute
On 26 October the US Tax Court has denied Coca-Cola’s motion for leave to file out of time a motion for reconsideration on the grounds that the application for leave would be “futile” as the court would, since the court will ultimately
See MoreUS and Turkey sign CAA regarding CbC exchange arrangement
On 24 November 2021, US and Turkey have signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. A CbC report is intended to be first exchanged with respect to Fiscal Years of MNE Groups commencing on or after 1
See MoreIndia: CBDT notifies the arm’s-length pricing variation limit for 2021-22
On 29 October 2021, the Central Board of Direct Taxes (CBDT) has published Notification No. 124/2021, which provides for a tolerance limit of 1% for wholesalers and 3% in all other cases for the arm’s-length pricing determination in the
See MoreTransfer Pricing Brief: December 2021
AustraliaCbC reporting requirement-Deadlines: On 18 November 2021, the Australian Taxation Office (ATO) announced that country-by-country (CbC) reporting entities that have a CbC reporting obligation due by 31 December 2021 will now have until 4
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