OECD: Transfer Pricing Implications of the Pandemic
On 18 December 2020 the OECD issued Guidance on the transfer pricing implications of the COVID-19 pandemic. This looks at the impact of the pandemic on areas of the transfer pricing analysis and APAs. Comparability analysis The pandemic and
See MoreEstonia: Parliament adopts Law on deferral of DAC6
On 12 December 2020, the Estonian Parliament has adopted the Tax Information Exchange Amendment Act on its website regarding deferral of DAC6. The Law entered into force on 4 December 2020, and shall be applied retroactively from 30 June
See MoreBulgaria: Government publishes new deadline for transfer pricing documentation
On 11 December 2020, the Bulgarian Government published the amendments to the Act on Tax and Social Security Procedure Code (TSPC) in the State Gazette. The National Assembly adopted an Act amending and supplementing the TSPC. According to the
See MorePeru joins CRS Multilateral Competent Authority Agreement
On 10 December 2020, the Organization for Economic Co-operation and Development (OECD) published an update regarding signatories of the multilateral competent authority agreement (MCAA) on automatic exchange of financial account information and
See MoreEstonia: Parliament adopts Bill to amend BEPS Multilateral Instrument (MLI)
On 9 December 2020, the Estonian Parliament (Riigikogu) has adopted Bill No. 286 SE to amend a Law on the Ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting. The Bill
See MoreCosta Rica: Ministry of Finance publishes new CIT rates for 2021
On 8 December 2020, the Costa Rican Ministry of Finance has published the Executive Decree No. 42733-H providing new corporate tax brackets for 2021. Decree No. 42733-H enters into force on 1 January 2021 and replaces the prior decree on rates
See MoreKenya publishes the law reversing the tax rates provided due to COVID 19
On 27 November 2020, the National Treasury has published the Tax Laws (Amendment) (No.2) Bill, 2020 (“the Bill”) in the Kenya Gazette Supplement No.216 (National Assembly Bills No.48). The law seeks to reverse the major tax concessions
See MoreNamibia deposits BEPS MLI ratification instrument
On 9 December 2020, Namibia 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 Namibia on 1 April
See MoreMalaysia: The Finance Bill 2020 includes transfer pricing measures
On 16 November 2020, Malaysia issued the Finance Bill 2020 (Bill No. DR 17/2020) including following proposals related to transfer pricing provision. Penalties for failure to prepare transfer pricing documentation There is currently no
See MoreGermany: Ministry of Finance publishes new transfer pricing guidance
On 3 December 2020, the Federal Ministry of Finance (BMF) has published the Administrative Principles 2020, which contain updated guidelines on audits / reviews of transfer prices between related parties and the responsibility of taxpayers to
See MoreSpain: Senate approves the law for the ratification of BEPS MLI
On 2 December 2020, the Spanish Senate adopted the law for the ratification of BEPS MLI. On 7 June 2017, Spain signed the Multilateral Instrument (MLI). Spain will need to deposit its ratification instrument to bring the MLI into force for its
See MoreDenmark: Government publishes an Act to set the timeline for filing TP documentation
On 9 December 2020, the Ministry of Taxation Officially published L 28 Proposal for a Law No. 1835 of 8 December 2020 to establish the timeline for filing transfer pricing (TP) documentation and amends the Corporation Tax Act and various other acts
See MoreAustralia: ATO releases final guidance on related party loan
On 10 December 2020, the Australian Taxation Office (ATO) issued final transfer pricing guidance on interest-free loans between related parties, in “Schedule 3 – Interest-free loans” to the ATO’s financing Practical Compliance Guideline
See MorePoland publishes law amending corporate income tax act
On 30 November 2020, the act amending the Corporate Income Tax Act was published in the Polish Journal of Laws and thus entered into force. The amendment introduces compliance of limited partnership having their management or registered office in
See MoreAustralia updates APA guidance
On 3 December 2020, the Australian Taxation Office (ATO) published an updated law administration practice statement about the advance pricing arrangements (APA) program. The updated guidance (PS LA 2015/4) reflects changes to the APA
See MoreDenmark: Parliament adopts a Law regarding transfer pricing
On 3 December 2020, the Parliament adopted the draft Bill No. L 28, which proposes to implement the OECD's recommendations on permanent establishment, so that the Danish rules are brought into line with the latest international standards. The
See MoreGermany publishes a law for the ratification of BEPS MLI
On 27 November 2020, Germany published the law in the Official Gazette to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Germany must now deposit its ratification
See MoreFinland: Tax authority publishes CbC reporting XML schema version 2.0
On 4 December 2020, the Finnish tax authority has updated its CbC reporting guidance concerning changes in the Country-by-Country (CbC) reporting XML schema to Version 2.0. Version 2.0 (Country-by-Country Reporting XML Schema 2.0) is released by
See More