Paraguay introduces new guidance on TP law
On 30 December 2020, the tax authority of Paraguay issued Decree 4644/2020, providing further guidance on the technical aspects of Paraguay’s transfer pricing (TP) provisions included in Law 6380. Law No. 6,380/2019 modernized the Paraguayan
See MoreSouth Korea enacts tax revision bill for 2021
At the end of December 2020, South Korea has enacted a tax revision bill for 2021, which was passed by Korea’s National Assembly on 2 December 2020. The tax revision bill generally effective from fiscal years beginning on or after 1 January 2021.
See MorePlatform for Collaboration on Tax: Toolkit on Implementing Transfer Pricing Documentation Requirements
On 19 January 2021 the Platform for Collaboration on Tax (PCT) published the “Practical Toolkit to Support the Successful Implementation by Developing Countries of Effective Transfer Pricing Documentation Requirements”. The PCT was set up by
See MoreDenmark: Court supports a decision on a case regarding intra-group deposits
On 18 January 2021, the National Tax Tribunal uphold a decision on a case of SKM2021.33.LSR regarding intragroup deposits with a group treasury entity, mentioning the taxpayer’s flawed documentation and differences in the interest rates charged
See MoreEstonia deposits BEPS MLI ratification instrument
On 15 January 2021, Estonia 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 will enter into force for Estonia on 1 May
See MoreSwitzerland: Review on international financial and tax matters of 2020
Switzerland’s Secretariat for International Finance (SIF) has published its annual review on international financial and tax matters for 2020. With respect to tax-related matters in particular, the review includes the following: Taxing
See MoreItaly introduces APA rollback
Budget Law 2021 contains new provisions on advance pricing agreement (APA) rollback. Multinational group taxpayers that had already agreed to APAs to address their transfer pricing can now rely on their retroactivity for tax periods still open for
See MoreBosnia and Herzegovina: BEPS MLI enters into force
The Multilateral Convention to execute tax agreement related measures to prevent base erosion and profit shifting (MLI) entered into force for Bosnia and Herzegovina on 1 January 2021. As regards the double taxation agreement (DTA) between Bosnia
See MoreOECD: Public Consultation on Tax Challenges of the Digital Economy
A public consultation meeting was held by the OECD on 14 and 15 January 2021 to discuss the proposals in relation to Pillar One and Pillar Two of the tax challenges of the digital economy. Following the publication of Blueprints on Pillar One and
See MoreItaly extends DST deadlines for FY 2020
On 15 January 2021, the Italian tax authorities published Provision no. 13185/2021 regarding the implementation the procedures for the collection of the 3% digital services tax (DST). The DST is effective from 1 January 2020 in Italy. The
See MoreThailand: Tax authority prolongs e-Filing deadline extension for 3 more years
On 15 January 2021, the Thai Ministry of Finance announced that the deadlines of the e-Filing and electronic tax payment will be extended for 8 more days, after the tax filing deadlines specified by the law. The extension will be effective for 3
See MoreAlgeria: Government publishes revised TP documentation requirements
On 2 January 2021, Government Officially published a Decree of 17 November 2020, which replaces the Decree of 12 April 2012. Initial transfer pricing documentation, which is submitted with the tax return, includes: Basic documentation regarding
See MoreBelgium initiates TP audit cycle of 2021
In the week commencing 11 January 2021, a number of selected Belgian taxpayers received a transfer pricing (TP) questionnaires from the tax authority’s special TP audit department. The questionnaire consists of around 30 questions, which reflects
See MoreColombia increases the value of tax unit for 2021
On 11 December 2020, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales-DIAN) has issued Resolution No. 000111 in the official website. The Resolution increases the tax unit value (Unidad de Valor Tributario - UVT)
See MoreLuxembourg: Tax Authorities issues guidance on interest deduction limitation
On 8 January 2021, the Luxembourg Tax Authorities has published Circular L.I.R. n° 168bis/1 (French), which clarifies certain aspects of the interest expense deduction limitation rules included in article 168bis of the Luxembourg Income Tax
See MoreSpain publishes state budget bill for fiscal year 2021
On 31 December 2020, Spain’s State Budget Bill for Fiscal Year (FY) 2021 (the Budget Bill) was published in the Spanish Official Gazette after its prior approval by the Spanish Congress and Senate. The main corporate tax measures are summarized
See MoreKenya: President signs the Tax Law Amendment Act (No. 2) of 2020
On 23 December 2020, the President of Kenya signed the Tax Law Amendment Act (No. 2) of 2020 which amends the Income Tax Act and the Value Added Tax (VAT) Act of Kenya. Critical changes include reinstating corporation tax
See MoreRussia updates mandatory audit thresholds
On 29 December 2020, Russia has published Federal Law No 476-FZ which amended the thresholds for mandatory tax audit with effect from 1 January 2021. The Federal Law increased the turnover threshold in the previous year to RUB 800 million
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