Hungary: 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
See MoreBelgium postpones DAC6 reporting deadline
On 28 January 2021, the Belgian Ministry of Finance has declared that due to the Covid-19 pandemic the Belgian tax authority will be postponing its reporting deadline without late submission penalties. The reporting deadline for historical
See MoreUruguay extends CbC reporting deadline to 28 February 2021
On 19 January 2021, Uruguay's Directorate General of Taxation (DGI) has published Resolution No. 075/2021 regarding the extension of the Country-by-Country (CbC) reporting deadline to 28 February 2021 for reporting fiscal years ending between 1
See MoreSwitzerland declares safe harbor interest rates
The Federal Tax Administration of Switzerland has published two separate circulars regarding safe harbor interest rate limits applicable to shareholder and related party loans in 2021. The rates may vary depend on whether the financing is in Swiss
See MoreMalaysia: IRBM reduces documentation submission timeline on request
On 2 February 2021, the Inland Revenue Board of Malaysia (IRBM) updated its transfer pricing guidelines including new guidance on submission of transfer pricing documentation and penalties. With the introduction of Section 113B of the ITA1967 which
See MoreLuxembourg updates the list of jurisdictions for exchanging CbC reports
On 26 January 2021, the Luxembourg Ministry of Finance published Grand-Ducal Regulation of 22 January 2021 in the Official Gazette amending Grand-Ducal Regulation of 13 February 2018. The Regulation updates the list of jurisdictions for
See MoreCyprus extends the deadline for the submission of DAC6 to 31 March 2021
On 3 February 2021, the Cyprus Tax Department has issued a notice regarding the extension to submission of DAC6. The Tax Department informs that the Directive is expected to be incorporated into the Cypriot legislation within the current month.
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