Morocco 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
See MoreCyprus: Tax department issues a notice extending penalty relief for DAC6 reporting
On 3 June 2021, the Cyprus tax department has issued a notice providing an extension to the imposition of administrative fines for overdue submission of DAC6 reporting. The Tax Department informs that there will be no imposition of
See MoreArgentina: Senate approves the bill regarding progressive CIT rates
On 2 June 2021, the Senate approved the revised draft bill, which introduces new progressive corporate income tax (CIT) rates starting from 1 January 2021. It was approved by the Chamber of Duties on 20 May 2021. According to the draft Bill, the
See MoreJordan introduces transfer pricing rules for MNE groups
On 7 June 2021, the Hashemite Kingdom of Jordan has published Regulation No. 40 of 2021 in the Official Gazette. The Regulation has introduced transfer pricing rules for multinational entity (MNE) groups with effect from 7 July 2021. The Regulation
See MoreVietnam: MoF implements new rules on Advance Pricing Agreements
On 18 June 2021, the Vietnamese Ministry of Finance (MoF) has issued Circular 45/2021/TT-BTC, which sets out new rules on Advance Pricing Agreements in Vietnam. The key measures of the Circular are listed below: Transactions covered by
See MoreGreece: Government publishes a Law to introduce new tax provisions
On 18 May 2021, the Government Officially published Law 4799/2021, introducing income tax reductions and other amendments to the Greek Income Tax Code. The Act includes some of the following provisions: Transfer pricing Enterprises
See MoreTransfer Pricing Brief: June 2021
ArgentinaTransfer pricing information return: On 30 April 2021, the Federal Administration of Public Revenue (AFIP) made an announcement that it will exceptionally extend the due date of submitting transfer pricing study and Form F. 2668 from June
See MoreColombia joins OECD International Compliance Assurance Programme (ICAP)
Recently, Organisation for Economic Co-operation and Development (OECD) has announced that Colombia joins International Compliance Assurance Programme (ICAP). ICAP is a voluntary risk assessment and assurance programme to facilitate open and
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Malaysia publishes new CbCR notification guidelines using Form C
On 25 May 2021, the Inland Revenue Board of Malaysia announced on its website that starting from the year of assessment (YA) 2021, constituent entities can now furnish the Country-by-Country Reporting (CbCR) Notification using the C Form.
See MoreFinnish Supreme Administrative Court makes a decision in a transfer pricing case
On 2 June 2021, the Finnish Supreme Administrative Court issued a decision regarding the acceptability of U.S. GAAP accounting standards as a basis for transfer pricing. Background The case concerned a Finnish company owned by a low-risk
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