South Africa: Court makes a decision regarding TP methods
On 7 January 2021, in the case of: ABC (Pty) Ltd v. Commissioner (IT 14305) ZATC 1, the South African Court upheld a transfer pricing adjustment for a taxpayer that failed to have transfer pricing documentation to support the arm’s
See MoreDenmark: Government introduces new anti-avoidance rule
On 27 January 2021, the Government submitted a draft bill L 150, which proposes to introduce two defensive measures against the countries on the EU list of non-cooperating tax jurisdictions. According to the proposal, the Law will enter into force
See MoreFrance: Government publishes a country list with no CbC reporting obligation
On 3 February 2021, Government published a Decree of 3 February 2021, amending the order of July 6, 2017 amended in accordance with II of article 223 quinquies C of the general tax code. The decree comes into force the day after its publication.
See MoreBelgium plans to launch further TP audit cycle
On 11 January 2021, a number of selected Belgian taxpayers received a transfer pricing (TP) questionnaires from the tax authority’s special TP audit department. Based on noncompliant TP forms again audit cycles will be launched by the special TP
See MoreQatar introduces TP declaration with tax return
The General Tax Authority (GTA) of Qatar has confirmed that taxpayers filing their income tax returns via the tax authority’s Dhareeba tax portal must also file a transfer pricing (TP) declaration of related-party transactions along with their
See MoreMalaysia releases updated tax guide on digital services
On 1 February 2021, the Royal Malaysian Customs Department published an updated Guide on Digital Services by Foreign Service Provider (FSP), which replaces the prior guide dated 1 August 2020. Effective 1st January 2020, service tax shall be
See MoreHungary: MOF publishes guidance on Mandatory Disclosure Rules
On 28 January 2021, the Hungarian Ministry of Finance published guidance on DAC6 reporting, which expands upon earlier guidance first issued in July 2020. The guidance serves as a general explanation on the provisions of the Hungarian MDR
See MorePoland: MOF announces a draft law introducing new advertising tax
On 2 February 2021, the Polish Government issued a draft introducing a new advertising tax (premium) on digital (internet) advertising and conventional advertising. The online advertising premium rate will be 5%. It will apply to advertisers whose
See MoreMexico sets threshold for reporting customized transactions under MDR
On 2 February 2021, Mexico has published Agreement 13/2021 in the Official Gazette. The Agreement sets threshold for reportable cross-border arrangements under the Mandatory Disclosure Regime (MDR). This Agreement is applicable from 3 February
See MoreIndia: Finance Minister presents the Union Budget 2021-22
On 1 February 2021, the Finance Minister presented the Union Budget 2021-22 containing following tax proposals. The budget proposed to reduces the length of time for assessment procedures from 24 months to 21 months (measured from the end of the
See MoreTransfer Pricing Brief: February 2021
AustraliaScope of transfer pricing rules: Australian Taxation Office (ATO) expanded the definition of “significant global entity (SGE)”. The SGE concept determines whether an entity is subject to a number of tax integrity and reporting
See MoreGreece publishes a Law for the ratification of BEPS MLI
On 26 January 2021, the Government Officially published Law No. 4768 to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Greece must now deposit its ratification
See MoreDominican Republic: DGII publishes thresholds for TP reporting and some tax issues
On 4 February 2021, the Directorate General of Internal Revenue (DGII) published Resolution No. DDG- AR1-2021-00002, which provides various tax issues, including new transfer pricing thresholds and updates to its tax haven list. Transfer pricing
See MoreIreland: Revenue issues eBrief regarding DAC6 reporting obligations
On 27 January 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 where certain
See MoreSaudi Arabia: GAZT publishes CbC reporting XML schema version 2.0
Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia has informed that Country-by-Country (CbC) Reporting Schema to V2.0 is being updated. Taxpayers have to submit (CbC) report via AEOI Portal using XML Schema standardized
See MoreAzerbaijan introduces CbC Reporting requirements
Recently, Azerbaijan has introduced Country-by-Country (CbC) reporting requirements and notification requirements for multinational entity groups (MNE groups) headquartered or operating in Azerbaijan. The CbC reporting rules are effective for
See MoreGreece: Revenue authority extends the DAC6 reporting submission deadline
On 27 January 2021, the Greek Public Revenue Authority (AADE) published Circular A. 1017 of 27 January 2021 regarding the delay of the initial reporting obligations for DAC6 cross-border arrangement. Under the Circular, the 30-day reporting period
See MoreLuxembourg Parliament approves Bill on the deduction of interest and royalties expenses
On 28 January 2021, the Luxembourg Parliament has approved Bill No. 7547 introducing a non-deductibility of interest or royalties paid to associate enterprises established in countries that are “blacklisted” as being “non-cooperative” for
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