Transfer Pricing Brief: October 2021
BotswanaDocumentation-Thresholds: On 1 September 2021, the General Commissioner published a ruling which sets the threshold for the preparation and submission of transfer pricing documentation. Accordingly, the obligation to prepare and submit
See MoreIndia extends the validity of transfer pricing safe harbor rules
On 24 September 2021, the CBDT issued a new Notification No. 117/2021, to extend the applicability of the transfer pricing safe harbor rules. The extension applies for the 2020-21 and 2021-22 assessment years. Taxpayers opting for safe harbor rules
See MorePuerto Rico: Treasury Department clarifies guidance on transfer pricing studies
On 20 September 2021, the Puerto Rico Treasury Department (PRTD) has issued Administrative Determination (AD) No. 21-08, which amends AD No. 21-05 of 11 May 2021. The AD 21-08 clarifies guidance on submitting transfer pricing studies (TPS). AD
See MoreWorld Bank: Conference looks at implementation of new tax instruments
On 1 October 2021 the second day of the Third World Bank Tax Conference looked at the practical implementation of new tax instruments. Sugar tax in South Africa The sugar-sweetened beverage tax in South Africa was first announced in the 2016
See MoreJordan issues Executive Instructions on new TP rules for MNE groups
On 16 September 2021, the Hashemite Kingdom of Jordan has published Executive Instructions No. 3 of 2021 regarding new transfer pricing (TP) rules for MNE groups. Jordan has published Regulation No. 40 of 2021 On 7 June 2021 which introduces
See MoreCyprus: MoF further extends the deadline for e-filing return
On 24 September 2021, Cyprus’s Ministry of Finance has issued a decree providing further extension of electronic submission of tax returns for business (TD4) and personal (TD1A) for the fiscal year 2019. The new deadline is 30 November 2021.
See MoreCyprus: Tax Department extends the DAC6 reporting deadlines
On 21 September 2021, the Tax Department of Cyprus has issued a notice extending the DAC6 reporting deadlines. Accordingly, there will be no imposition of administrative fines for overdue submission of DAC6 information that will be submitted until
See MoreUkraine: STS clarifies the controlled transactions criteria for TP purposes
Recently, the State Tax Service (STS) has clarified the criteria for classifying transactions between related parties (Ukrainian residents and non-residents) as controlled for transfer pricing (TP) purposes. Under Ukrainian transfer pricing
See MorePhilippines: House of Representatives approves digital service tax
On 21 September 2021, the House of Representatives approved on final reading a proposal imposing a 12% value-added tax (VAT) on digital transactions in the country to generate new funding sources for the country's Covid-19 response efforts. The
See MoreOECD: Model Manual on Exchange of Information
On 16 September 2021 the Global Forum on Transparency and Exchange of Information for Tax Purposes, the World Bank Group and the African Development Bank issued a new version of the Manual on Exchange of Information. The previous version of the
See MoreNetherlands presents Budget for 2022
On 21 September 2021, the Dutch Budget for 2022 was presented. This year, the 2022 tax plan package mainly contains minor changes aimed at improving the tax system. In particular, improvements will be made to existing taxes in the areas of housing,
See MoreItaly launches public consultation on draft circular on TP documentation requirements
The Italian tax authorities have introduced a public consultation on the draft circular clarifying transfer pricing (TP) documentation requirements. Comments should be submitted by 12th October 2021 to the email
See MorePeru sets CbC reports ‘secondary filing’ for US parent entities located in Peru
There is no automatic exchange of country-by-country (CbC) reports agreement between Peru and the United States (US). So the US parent entities located in Peru will be required secondary filing by mid-October 2021 for the fiscal year 2020. The
See MoreUkraine: MOF approves three Orders on transfer pricing and other taxes
On 20 August 2021, the Ukraine Ministry of Finance announced the issuance of three orders that approve tax clarifications/consultations on: Issues of taxation of income of non-residents, which are equated to dividends (Order №
See MoreThailand extends tax refunds deadline in MAP cases
On 23 August 2021, the Ministry of Finance of Thailand has issued a notification that provides an extension of the deadline to request a corporate or individual income tax refund for certain eligible persons whose standard time to request a tax
See MoreColombia approves new Tax Reform Bill 2021
On 14 September 2021, Colombia has approved the new Tax Reform Bill 2021 (Law No. 2155 of 2021) which modifies corporate income tax (CIT), value-added tax (VAT), and tax incentives. The main tax measures of the Tax Reform Bill are as
See MoreIreland: Government publishes Tax Strategy Group Papers prior to Budget 2022
On 16 September 2021, the Finance Department and the Department of Employment Affairs and Social Protection published Tax Strategy Group papers prior to Budget 2022. Some of the changes in the Budget papers are given below: Corporate tax As
See MoreIMF: Tax and Digitalisation in Asia
On 14 September 2021 the IMF held a digital seminar on Tax and Digitalisation in Asia, coinciding with the launch of an IMF paper on the same subject (Departmental Paper No 2021/017). Currently the most highly digitalised companies often escape
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