Transfer Pricing Brief: September 2021
ChinaAPAs-Unilateral: On 26 July 2021, the State Administration of Taxation (SAT) issued Announcement No. 24 (2021) that finalizes a simplified procedure for unilateral advance pricing arrangements (APAs), which will come into effect on 1 September
See MoreGermany publishes Guidance on MAP and arbitration procedures
On 27 August 2021, the Federal Ministry of Finance published guidance on mutual agreement (MAP) and arbitration procedures. The guide explains how to initiate procedures, how to carry out procedures, how to execute agreements, etc. The guidance
See MoreIndia extends the due dates for E-filing of various forms
On 29 August 2021, the CBDT published circular No. 16/2021 to extend the deadlines for the electronic submission (E-filing) of various forms. Accordingly, the due date for filing the CbC report notice (i.e. Form 3CEAC) may be submitted on or before
See MoreNigeria: FIRS suspends CbC report local filing for non-parent entities
In September 2013, the Organization for Economic Co-operation and Development (OECD) and G20 countries, working together on an equal footing, adopted an ambitious and comprehensive 15-point Action Plan to address BEPS. The Action Plan aims to
See MoreQatar: GTA extends deadline for filing tax returns
On 30 August 2021, the General Tax Authority (GTA) of Qatar has announced the extension of deadline for submitting tax returns for fiscal year 2020 for companies and establishments owned by Qatari citizens and GCC citizens, which are exempt from
See MoreUS: IRS publishes joint statement with Germany on the exchange of CbC reports
The Internal Revenue Service (IRS) published a joint statement with the competent authority of the United States of America and the competent authority of the Germany on the implementation of the spontaneous exchange of Country-by-Country Reports
See MoreUS: IRS publishes joint statement with France on the exchange of CbC reports
The Internal Revenue Service (IRS) published a joint statement with the competent authority of the United states of America and the competent authority of the French republic on the implementation of the spontaneous exchange of country-by-country
See MoreFinland: MOF launches public consultation on transfer pricing adjustment
On 21 August 2021, the Finland’s Ministry of Finance has launched a public consultation on draft bill concerning the revision of the Finnish transfer pricing adjustment provision. The draft law includes measures that: 1) align the
See MoreThailand extends CIT return filing deadline
The Thai Ministry of Finance (MOF) has extended the deadlines for electronic filing of corporate income tax (CIT) return in response to the Covid-19 pandemic. The corporate income tax return (PND 50, 52 and 55), financial statements and the
See MoreIndia: CBDT notifies a formula to adjust MAT relief for secondary adjustment and APA
On 10 August 2021, the Central Board of Direct Taxes (CBDT) has published Notification No. 92/2021, which contains a new rule for calculating tax relief in the event of an increase in book profit as a result of adjustments to Advance Pricing
See MoreRomania approves BEPS MLI
On 19 August 2021, Romania approved the ratification of the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI). Romania must deposit its ratification instrument to bring the MLI into
See MoreSri Lanka issues TP disclosure form for AY 2020/2021
On 16 August 2021, the Inland Revenue Department (IRD) of Sri Lanka published the transfer pricing disclosure form for the assessment year (AY) 2020/2021. Entities are required to file the TP disclosure form with their annual income tax return if
See MoreGermany updates the CbC Reporting requirements based on the Annual Tax Act 2020
The Federal Ministry of Finance recently published a notice on the current issue of the Federal Central Tax Office's newsletter, which updates the country-specific (CbC) reporting requirements due to the 2020 Annual Tax Act. As a result of the
See MoreEU: Commission Letter Comments on Common Corporate Tax
On 3 August 2021 a letter addressed to the European Parliament on behalf of the European Commission confirmed that the single corporate tax system for the EU, to be known as Business in Europe: Framework for Income Taxation (BEFIT), would take into
See MoreDenmark proposes to reduce the TPD obligation for purely Danish transactions
On 23 June 2021, the Ministry of Finance submitted a draft bill for consultation. The bill proposed an amendment to the Danish Tax Control Act in order to relax the documentation requirements for transfer pricing for purely Danish transactions. It
See MoreDominican Republic: DGII invites for public comments regarding CbC reporting requirements
Recently, the Directorate General of Internal Revenue (DGII) declared a public consultation on a draft general standard regarding country-by-country (CbC) reporting. The DGII invited for public comments up to 7 September 2021. The CbC report
See MoreSingapore releases updated Transfer Pricing Guidelines
On 10 August 2021, the Inland Revenue Authority of Singapore published the sixth edition of its E-Tax Guide on Transfer Pricing. The most important changes are summarized as follows: Additional guidance on cost contribution arrangements (CCAs)
See MoreLuxembourg updates electronic exchange and frequently asked questions of CbC report
On 20 August 2021, Luxembourg has announced that the section "Electronic exchange - country by country (CbC) reporting" as well as the frequently asked questions relating to the CbC declaration have been updated. Please note that the frequently
See More