US: 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
See More
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
See MoreLuxembourg: Circular provides updated guidance on interest deduction limitation
On 2 June 2021, the Luxembourg Tax Authorities has published Circular L.I.R. n° 168bis , which clarifies certain aspects of the interest expense deduction limitation rules included in article 168bis of the Luxembourg Income Tax Law (ITL). The
See MoreSingapore updates GST Guide on Transfer Pricing Adjustments
On 1 June 2021, the Inland Revenue Authority of Singapore (IRAS) has published second edition of e-Tax Guide GST: Transfer Pricing Adjustments. The e-Tax guide explains the GST treatment for adjustments on the transfer prices of transactions
See MoreBangladesh: Budget proposal for FY 2021-2022
On 3 June 2021, Mr. AHM Mustafa Kamal, the Finance Minister of Bangladesh presented the national budget for fiscal year (FY) 2021-2022 in the parliament. The budget set the target for total revenue collection in the FY 2021-2022 at Tk. 389,000
See MoreTurkey ensures effective date of MCAA of CRS and CbC Reports
On 31 May 2021, Turkey has published Decision No. 4025, and Decision No. 4026, which set the effective date of the Multilateral Competent Authority Agreement (MCAA) of Common Reporting Standard (CRS) and Country-by-Country (CbC)
See MoreOECD: Tax Transparency in Africa 2021
On 26 May 2021 the OECD published Tax Transparency in Africa 2021. The 2021 edition indicates that there has been progress in African countries on development of capacities in tax transparency and exchange of information (EOI); and progress in
See MoreNigeria: FIRS issues a notice to suspend CbC reporting obligations for MNE branches
The Federal Inland Revenue service (FIRS) issued a public notice to suspend Regulation 4 of the “Income Tax (CbC Regulations) Regulations, 2018”. This public notice notifies branches and subsidiaries of Multinational Enterprises (MNEs)
See More