South Africa: SARS publishes list of jurisdiction with effective CbC report exchange agreements
The South African Revenue Service (SARS) published a latest list of jurisdictions. These listed jurisdictions have CbC report exchange agreements with South Africa from 22 June 2021. The lists are intended to assist members of MNE Groups tax
See MoreIceland publishes a law on new penalties for transfer pricing documentation
On 15 June 2021, Iceland published Law 61/2021 in the Official Gazette introducing new rules for the imposition of fines on taxpayers who fail to comply with transfer pricing documentation requirements for related party transactions, whether
See MoreMalaysia: BEPS MLI enters into force
On 29 June 2021, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, the MLI entered into
See MoreCroatia: BEPS MLI enters into force
On 29 June 2021, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, the MLI enters into
See MoreCanada: CRA replaces and abolishes a Circular regarding MAP
On 1 June 2021, the Canada Revenue Agency (CRA) published Information Circular IC71-17R6, which replaces and cancels Information Circular 71-17R5 dated January 1, 2005. This Circular describes several changes related to MAP. MAP filing
See MoreTaiwan: MOF issues Decree on cross-border bilateral, multilateral APAs under MAP
On 24 June 2021, the Ministry of Finance issued a Decree which stipulates that when tax collection authorities negotiate cross-border bilateral or multilateral advance pricing arrangements (APAs) (hereinafter referred to as "BAPAs") with the
See MoreOECD: Global Forum publishes peer review reports on transparency and exchange of information
On 24 June 2021 the Global Forum published peer review reports on transparency and exchange of information for five more countries. The peer review reports examine the legal and regulatory framework in each country and its compliance with the
See MorePortugal extends CIT return submission deadline and preparation of TP documentation
According to the Order No. 191/2021-XXII of 15 June 2021, Portugal has extended the tax compliance deadlines in response to the Covid-19 pandemic, as follows: The annual corporate tax return (Modelo 22) submission and respective payment deadline
See MoreOECD: Model Reporting Rules for Digital Platforms: International Exchange Framework
On 22 June 2021 the OECD published an international exchange framework in relation to the model platform reporting rules for sellers in the sharing and gig economy. The Multilateral Competent Authority Agreement on Automatic Exchange of
See MoreMorocco publishes guidance on mutual agreement procedure
The Ministry of Finance (MoF) of Morocco has published guidance on the mutual agreement procedure (MAP), which provides a dispute resolution procedure to resolve tax treaty related disputes. MAP is designed to relieve double taxation, typically
See MoreAzerbaijan signs MCAA for the exchange of CbCR
On 12 March 2021, Azerbaijan has signed the Multilateral Competent Authority Agreement (MCAA) for the exchange of Country-by-Country reports (CbCR). According to OECD, the total signatories to the agreement CbC MCAA are now
See MoreArgentina: AFIP extends the deadline of TP filing reports
On 18 June 2021, the Federal Administration of Public Revenues (AFIP) Officially published General Resolution 5010/2021, which extends the deadline for filing transfer pricing reports and related forms F. 2668 and F. 2672 for tax years ended
See MoreSpain publishes an order on tax return in relation to DST
On 11 June 2021, Spain published the form 490 for the digital services tax that was approved on 9 June 2021. In this declaration, taxpayers must indicate the group to which they belong, their total income, if any, and the tax base by category of
See MoreQatar extends master and local file submission deadline to 30 September 2021
On 17 June 2021, the General Tax Authority (GTA) of Qatar published Decision No. 8 of 2021 extending the deadline for submission of the Master file and Local file from 30 June 2021 to 30 September 2021 for the 2020 fiscal year. Furthermore,
See MoreUK: Finance Act 2021 increases corporate tax rate and extends loss carry-back provision
On 10 June 2021, the UK’s Finance Act 2021 received royal assent and was published in the Official Gazette. Some of the Key tax measures are following: The corporate tax rate will increase to 25% from April 2023 on profits over £250,000.The
See MoreUS: Coca-Cola requests tax court to reconsider transfer pricing dispute
On 2 June 2021, the Coca-Cola Company has requested the US Tax Court to reconsider a transfer pricing tax ruling that was given on 18 November 2020. Upon examination of the company’s 2007-2009 returns, IRS found that the company’s
See MoreSpain publishes a decree amending Mutual Agreement Procedure (MAP)
On 8 June 2021, the Spanish government has published a Royal Decree 399/2021 which amends the Regulation on Mutual Agreement Procedures (MAP) as approved by Royal Decree 1794/2008. The decree implements three packages of initiatives to enhance
See MoreUAE publishes guidance on mutual agreement procedure
The Ministry of Finance (MoF) of the United Arab Emirates (UAE) has published guidance on the mutual agreement procedure (MAP), which provides a dispute resolution procedure to resolve tax treaty related disputes. MAP is designed to relieve
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