Romania revises number of large taxpayers required to prepare TP documentation
On 29 October 2021, the Romanian National Tax Agency (NTA) published Order No. 1721 that revises the list of large taxpayers those are subject to prepare transfer pricing (TP) documentation. There are currently 2,940 large taxpayers until 31
See MoreTaiwan notifies affiliates of MNEs on submission of Master File and CbC report
On 9 November 2021, Taiwan’s National Tax Bureau of the Southern Area has indicated that affiliates of multinational enterprises in Taiwan, which meet the threshold to submit Master File or Country-by-Country (CbC) Report, shall not only disclose
See MoreColombia issues Draft Resolution to set UVT for 2022
On 8 November 2021, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales-DIAN) has issued a Draft Resolution to set out the tax unit value (Unidad de Valor Tributario – UVT) applicable for the year 2022. The UVT is
See MoreFinland: Parliament adopts bill to amend cross-border hybrid mismatch rules
On 29 October 2021, the Parliament of Finland has adopted the Bill No.204/2021 to amend cross-border hybrid mismatch rules, implementing the EU anti-avoidance directives. The bill includes following measures to transpose the reverse hybrid mismatch
See MoreColombia: Government issues regulations identifying preferential tax regimes
On 28 October 2021, the Colombian Government has issued Decree 1357, through which it partially regulates article 260-7 of the Tax Code. The Decree identifies criteria to consider a jurisdiction as a Preferential Tax Regime. This decree was
See MorePeru: Government submits Tax Reform Bill to Congress
On 27 October 2021, the Government led by President Pedro Castillo has submitted a bill to Congress through which it requests extraordinary powers to legislate on tax matters. The main measures of the Bill are as follows: Increase of capital
See MoreUK: New Tax Regime for Asset Holding Companies
The UK budget announcements on 27 October 2021 proposed that legislation would be included in the Finance Bill 2021/22 to set up a new tax regime for qualifying asset holding companies (QAHCs). This change is part of a broader review of the UK
See MoreUK: Notification of Uncertain Tax Treatment for Large Businesses
The UK budget announcements on 27 October 2021 included a new requirement for large businesses to notify HMRC when they take a tax position in their returns that is uncertain. Legislation would be included in the Finance Bill defining a large
See MoreNigeria issues new procedural rules for tax appellate tribunal
Recently, the Minister of Finance, Budget and National Planning issued new Tax Appeal Tribunal (Procedure) Rules 2021. The Rules replace the 2010 Rules and are intended to guide the practice and procedure of Tax Appeal Tribunal (“TAT“)
See MoreUkraine: Cabinet of Ministers adopts new APA procedures
On 28 October 2021, the Cabinet of Ministers of Ukraine has adopted new procedures of preliminary coordination of advance pricing agreements (APAs) in controlled transactions, as a result of which agreements on preliminary coordination of pricing,
See MoreCyprus: Tax department publishes decree implementing regulations for DAC6
On 29 October 2021, the tax department of Cyprus published the Decree KDP 438/2021 for the implementation of the EU directives on reportable cross-border arrangements (DAC6). The decree provides guidance on the participants in a reportable
See MoreTransfer Pricing Brief: November 2021
AustriaDocumentation-Requirement: On 7 October 2021, the Austrian Ministry of Finance published the updated Austrian Transfer Pricing Guidelines (Austrian Guidelines) 2021. The guideline provided guidance for those companies which fall under the
See MoreSingapore: IRAS updates e-Tax Guide on DTA to address arbitration procedure
On 23 October 2021, the Inland Revenue Authority of Singapore (IRAS) issued an updated edition of its e-tax guide on “avoidance of double taxation agreements” to add guidance on arbitration provisions in Singapore’s double tax
See MoreTurkey issues Regulations on mutual agreement procedures (MAP)
On 26 October 2021, Turkey has published Law No. 7338 on Certain Amendments on Tax Procedural Law and Certain Laws in the Official Gazette which clarifies provisions with respect to the domestic application of the mutual agreement procedure
See MoreGermany publishes court ruling on the arm’s-length interest rate on intercompany loans
On 21 October 2021, the German Ministry of Finance released Tax Court Decision No. IR 4/17(dated 18 May 2021), regarding the calculation of an arm's-length interest rate on intercompany loans. Under the ruling, the interest rate should be based
See MoreIreland adopts OECD authorized approach for TP of branches
On 21 October 2021, Minister for Finance, Paschal Donohoe TD, published the draft Finance Bill 2021, which underpins the Government’s ongoing support for the economy, particularly in response to the impact of Covid-19. It will introduce the
See MoreThailand introduces CbC reporting
On 15 October 2021, the Thai Revenue Department released guidance concerning the transfer pricing requirements with regard to country-by-country (CbC) reporting for accounting periods beginning on or after 1 January 2021. The guidance is referred
See MoreUN: Tax Committee Discusses Transfer Pricing Issues
In its virtual meetings from 19 to 27 October 2021 the UN Tax Committee is considering aspects of transfer pricing. Among topics that could be pursued further are practical risk assessment tools, transfer pricing aspects of marketing or trading
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