Cyprus 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
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
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