Italy clarifies TP documentation requirements
On 26 November 2021, the Italian Tax Authorities issued Circular No. 15 providing clarifications on the regulations introduced on 23 November 2020 regarding the content and validity of the elective transfer pricing (TP) documentation available to
See MoreSri Lanka declares CbC notification deadline for FY 2021
On 25 November 2021, the Inland Revenue Department (IRD) has issued a notice as per the paragraph (e) of Regulation 6 of the Extra Ordinary Gazette Number 2217/7 dated 02.03.2021, MNE Group whose total consolidated group revenue is not less than
See MoreTaiwan: MOF reminds taxpayers for submitting MF and CbC report by December 31st
On 30 November 2021, Taiwan’s Ministry of Finance (MOF) has issued a press release as a reminder to the taxpayers for submitting Master Files (MF) and Country-by-Country (CbC) reports. The profit-seeking enterprises that meet the conditions
See MoreUK: Responses to Consultation on Transfer Pricing Documentation
On 30 November 2021 the UK government published a summary of responses to the consultation on transfer pricing documentation held earlier in 2021. The original consultation invited comments from interested parties on whether there should be a
See MoreDenmark approves the bill to relax rules on TP documentation
On 25 November 2021, the Danish Parliament passed Draft Law No. L7, which largely abolishes the obligation to include domestically, controlled transactions in the Transfer Pricing Documentation (TP). The draft law also specifies the requirement to
See MoreEstonia deposits new notifications under the BEPS MLI
On 25 November 2021, the Organization for Economic Cooperation and Development (OECD) has announced that Estonia deposited new notifications under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and
See MoreRussia: MOF publish clarification guidance for TP purposes
On 18 November 2021, the Russian Ministry of Finance (MoF) published a Guidance Letter No. 03-03-07/85525 clarifying that a loan is considered a controlled debt for Transfer Pricing (TP) purposes if it is granted to a Russian company by a third
See MoreOECD: New MAP statistics for 2020
On 22 November 2021 the OECD released updated mutual agreement procedure (MAP) statistics for 2020. The statistics cover 118 jurisdictions and include almost all MAP cases globally. The collection of the MAP statistics is one element in the minimum
See MoreCyprus extends the imposition of administrative fines for DAC6 reporting
On 22 November 2021, the Cyprus Tax Department has published an announcement extending administrative fines for overdue submission of DAC6 reporting. The Tax Department informs that there will be no imposition of administrative fines for overdue
See MoreUS and India reach agreement on ‘equalization levy’ digital services tax
On 24 November 2021, the United States and India concluded an agreement on a transitional approach to the treatment of the current Indian E-commerce Equalization Levy (EL) in the transition period prior to the full implementation of Pillar 1
See MoreUS and Turkey sign digital service tax agreement
On 22 November 2021, the U.S. treasury department announced that the United States and Turkey have reached a political agreement with Turkey on the treatment of taxes on digital services (DST) in the transition period prior to the full
See MoreAzerbaijan modifies the Tax Code for TP, CbC Reporting, and CFC rules
On 16 November 2021, Azerbaijan has modified its Tax Code including three main changes regarding Transfer Pricing (TP), country by country (CbC) reports, and controlled foreign company (CFC) rules. The changes will be implemented from 1 January
See MoreKenya: KRA invites public comments on draft CbC reporting regulation
On 19 November 2021, Kenya Revenue Authority has opened a consultation on a country-by-country (CbC) reporting regulation. Accordingly, the National Treasury and Planning and Kenya Revenue Authority would like to inform Multinational Enterprises
See MoreMalta: CFR updates guideline on DAC6 reporting
On 17 November 2021, the Commissioner for Revenue (CFR) notifies that version 1.1 of the updated Guidelines on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements (DAC 6) are available for download here. Updates
See MoreSouth Africa: Parliament tables 2021 Tax Bills
On 11 November 2021, Tax Bills 2021 (Taxation Laws Amendment Bill (TLAB), Tax Administration Laws Amendment Bill (TALAB), Rates and Monetary Amounts and Amendment of Revenue Laws Bill (Rates Bill)) were tabled in the Parliament. The National
See MoreAustralia extends CbC reporting deadline
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 February 2022 to file (lodge) such CbC reporting
See MoreSpain: Budget-2022 sets new minimum corporate tax rate
On 4 November 2021, the Spanish lower chamber passed the budget for 2022 which provides for a minimum corporate tax rate of 15% of the tax base for certain taxpayers from 2022. It applies to companies with a net turnover of at least 20 million
See MoreGermany publishes court decisions concerning the intercompany loans
On 4 November 2021, The German Ministry of Finance (MoF) published Tax Court Decision No. IR 32/17of 9 June 2021, on the taxation of corporate income based on unsecured loans to foreign related companies. In that case, a domestic company granted
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