Zambia 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
See MoreIreland: Revenue issues an eBrief to announce updated TP guidance
On 24 February 2021, the Irish Revenue issued eBrief No. 37/21 regarding updated guidance on transfer pricing. On the similar day, the Revenue also published a Tax and Duty Manual-Part 35A-01-01, providing updated guidance on the operation of the
See MoreIndia further extends the deadlines for audit, reassessment and penalty proceedings
On 27 February 2021, the Central Board of Direct Taxes (CBDT) released a Notification No. 10/2021 that provides the further extension of deadlines for the completion of audit, reassessment, and penalty proceedings due to COVID-19
See MoreTurkey further extends CbC report filing deadline
On 22 February 2021, the Turkish Revenue Administration has issued Circular TF-3/2021-1 by which Turkey extends Country-by-Country (CbC) report filing deadline. Previously, Turkey extends CbC report filing deadline to 26 February 2021. The new
See MoreHungary ratifies BEPS MLI
On 22 February 2021, the Hungarian Parliament approved the bill for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI will generally enter into
See MoreThailand requires TP disclosure form to be submitted electronically
On 14 January 2021, the Revenue Department of Thailand has published a notice making it mandatory for companies to submit their transfer pricing (TP) disclosure forms via the Revenue Department's website or the Ministry of Finance's electronic tax
See MoreSouth Africa: SARS extends the CbC report submission deadline
On 19 February 2021, the South African Revenue service (SARS) Officially published Public Notice No. 101, which stated that the due date for submitting country-by-country (CbC) report is extended on the basis of some specified person. According to
See MoreUkraine: MOF approves the procedure for submitting CbC report
On 19 February 2021, the Ukrainian Ministry of Finance (MOF) has issued a press release where they clarify the procedure for submitting Country-by-Country (CbC) report. The Order of the Ministry of Finance No. 764 dated 14 December 2020, which
See MoreLuxembourg: Tax Authorities modifies guidance on DAC6
On 17 February 2021, the Luxembourg Tax Authorities has modified guidelines concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) as per Council Directive (EU) 2018/822 of 25 May 2018. The following headings
See MoreUganda commits to implement AEOI by 2023
On 17 February 2021, OECD has announced that Uganda has committed to implement the International Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI) by 2023. Maria José Garde, Chair of the Global Forum, said
See MoreOECD: BEPS Action 5 Peer Review Transparency Framework
On 22 February 2021 the OECD issued a report outlining the details of the new peer review framework for the peer reviews under Action 5 of the OECD/G20 action plan on base erosion and profit shifting (BEPS). Action 5 relates to action to combat
See MoreCroatia deposits BEPS MLI ratification instrument
On 18 February 2021, the OECD announced that Croatia has deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI enters into force for
See MoreOECD: ICAP Handbook Released
On 18 February 2021 the OECD issued the International Compliance Assurance Programme Handbook for Tax Administrations and MNE groups. The International Compliance Assurance Programme (ICAP) was set up as a voluntary risk assessment and assurance
See MoreFrance: Court makes decision to reflect intra-group financial transactions
The French tax administration (FTA) published some decisions issued by the French courts and an administrative guidance regarding the arm’s length nature of intragroup financial transactions. Court’s decisions: In the last quarter of
See MoreCroatia: Government fixes related party interest rate for 2021
The Croatian Government has changed the arm’s length interest rate from 3.42% per annum to 3% per annum regarding loans between related parties for the year 2021. This rate is effective from 1st January 2021 and applies for loans between resident
See MoreCanada: CRA announces not to pay cost recovery charge for APAs
On 5 February 2021, the Canada Revenue Agency (CRA) announced that they will no longer require taxpayers to provide a cost recovery charge when entering the Advance Pricing Arrangement (APA) program. Previously, the charge was used to cover the
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