Belgium extends CIT return submission deadline for FY 2020
On 18 March 2021, the Belgian tax authorities extended the corporate income tax (CIT) return submission deadline to 28 October 2021 for financial years ended between 31 December 2020 and 28 February 2021 in response to the Covid-19 pandemic. As
See MoreUK: Consultation on Transfer Pricing Documentation
On 23 March 2021 the UK government published a consultation paper on transfer pricing documentation. The closing date for comments is 1 June 2021. Following the final report on Action 13 of the OECD Action Plan on base erosion and profit
See MorePanama extends tax return submission deadline for 2020
The Ministry of Economy and Finance of Panama has extended the deadline to 3 May 2021 for the submission of income tax returns (natural and legal persons) for the tax year 2020 in response to the Covid-19
See MoreSerbia: MOF releases arm’s length interest rates for 2021
On 19 March 2021, the Serbian Ministry of Finance has published the Rulebook on Arm’s Length Interest Rates applicable for 2021 that applies on related parties’ loans. Rulebook comes into force on 27 March 2021. Taxpayers can use
See MoreLuxembourg: Tax Authorities issues circular on updated MAP guidance
On 11 March 2021, the Luxembourg Tax Authorities has issued Circular L.G. - Conv. D.I. n° 60 regarding the updated mutual agreement procedure (MAP) guidance. The Circular replaces previous Circular L.G. Conv. D.I. No. 60 of 28 August 2017. The
See MoreGreece: AADE publishes a guide regarding the COVID-19 effects on TP issues
On 10 March 2021, the Greek Public Revenue Authority (AADE) published Circular Ε. 2054 of 10 March 2021, providing general guidance of how to deal with the adverse effects of the COVID-19 pandemic on transfer pricing issues. The guidance is
See MoreCyprus extends the deadlines for electronic submission of tax returns
On 12 March 2021, Cyprus’s Minister of Finance has published a decree extending the deadline for submission of certain direct tax returns. Accordingly, the deadline for electronic submission of the 2019 corporate tax return (T.D.4) has been
See MoreHungary publishes law for the ratification of BEPS MLI
On 3 March 2021, the Hungarian President ratified the law, that was approved by the Hungarian Parliament on 22 February 2021, and promulgated the MLI in Hungary. The ratification process was completed on 4 March 2021 by publishing the approved bill
See MoreDominican Republic: DGII declares public consultation to amend TP rules
On 1 March 2021, the Directorate General of Internal Revenue (DGII) made an announcement of launching a public consultation on the draft modification of articles 5, 7, 10 and 18 of the transfer pricing (TP) regulation, established by means of the
See MoreCzech Republic: Finance ministry extends tax return filing deadline
On 9 March 2021, the Government published Financial Bulletin No. 16/2021, including a decision from Finance Ministry that the submission deadline of income tax return 2020 in paper format is extended from 1 April 2021 until 3 May 2021. On the other
See MoreChile: BEPS MLI enters into force
On 1 March 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, MLI entered into
See MoreTransfer Pricing Brief: March 2021
AzerbaijanCbC reporting requirement-General rule: Recently, Azerbaijan has introduced CbC reporting requirements and notification requirements for multinational entity groups (MNE groups) headquartered or operating in Azerbaijan. The CbC reporting
See MoreItaly further extends DST deadlines for FY 2020
On 9 March 2021, the Ministry of Economy and Finance of Italy announced the further extended deadlines for filing the digital services tax (DST) return and payment of tax for FY 2020. The new deadlines for FY 2020 DST are as follows: 16 May
See MoreGeorgia: MOF publishes decree amending transfer pricing rules for APAs
On 2 March 2021, the Georgian Ministry of Finance published Decree No.45 amending the Georgian transfer pricing rules regarding the Unilateral Advance Pricing Agreement (APA). The decree amends the APA clauses, most importantly reducing the filing
See MoreIreland: Revenue publishes an eBrief to update DAC6 reporting guidance
On 1 March 2021, the Irish Revenue published an eBrief No. 014/21 regarding EU mandatory disclosure of reportable cross-border arrangements. On the similar day, the Revenue also published a Tax and Duty Manual, providing guidance to update the DAC6
See MoreZambia introduces CbC Reporting requirements
On 31 December 2020, Zambia has published The Income Tax (Transfer Pricing) (Amendment) Regulations under Statutory Instrument No. 117 of 2020. The Regulations introduce country-by-country (CbC) reporting requirements, which are effective from 1
See MoreCanadian mining company wants to resolve its tax dispute with NAFTA arbitration
On 2 March 2021, a publicly traded Canadian mining company (First Majestic Silver), has resorted to international arbitration to resolve an ongoing transfer pricing dispute with the Mexican government over tax reassessments the government made in
See MoreQatar introduces new TP documentation requirements
On 16 July 2020, the General Tax Authority (GTA) of Qatar has issued Decision No. 4 of 2020 and made public on 1 March 2021, which confirms the obligation to submit the transfer pricing (TP) disclosure form, master file, and local file applies to
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