Ukraine: 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
See MoreGreece: Tax Authority describes interest deduction limitation rules
On 11 January 2021, the Greek Public Revenue Authority (AADE) published Circular Ε. 2004 of 11 January 2021, which describes the application of the rule of limitation of interest as amended from 1 January 2019. According to the Circular, the
See MoreOECD: Final Batch of Stage 1 Peer Review Reports on Dispute Resolution
On 16 February 2021 the OECD issued the final batch of stage 1 peer review assessments in relation to BEPS Action 14 on making dispute resolution mechanisms more effective. Countries that are members of the OECD’s Inclusive Framework on BEPS
See MoreQatar: Request to extend CIT return submission deadline by 28 February 2021
Generally, corporate income tax (CIT) filing deadline for year ended 31 December 2020 will be 30 April 2021. According to the Article 30 of the executive regulations of the Income Tax Law No. 24 of 2018, the General Tax Authority (GTA) may grant an
See MoreSouth 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 More