Singapore updates indicative margins for related party loans
The Inland Revenue Authority of Singapore (IRAS) has published updated indicative margins for related party loans. IRAS has introduced an indicative margin which taxpayers can apply on each related party loan not exceeding S$15 million as tabulated
See MoreMorocco revises TP documentation penalty
On 18 December 2020, the Ministry of Finance of Morocco has published the Finance Law for 2021 in the Official Gazette, apply from 1 January 2021. Morocco's Finance Law 2021 introduced new transfer pricing (TP) documentation
See MoreBulgaria: Government reveals tax measures included in 2021 Budget
On 8 December 2020, the Government Officially published a Law, which provides tax measures included as part of the 2021 Budget. The key measures are given below: The Law introduced new deadline for filing annual corporate income tax returns up
See MoreArgentina: AFIP further extends the deadline for beneficial ownership declaration
On 31 December 2020, the Federal Administration of Public Revenue (AFIP) Officially published General Resolution 4897/2020 of 29 December 2020, which extends the initial reporting deadline of beneficial ownership declaration for 2019 and, with
See MoreGreece: MoF extends the deadline for beneficial ownership declaration
On 30 December 2020, a decision of the Deputy Minister of Finance, Mr. George Zavvos, was signed, which extends the deadline for the registration of beneficial ownership (UBO) information in the UBO registry from 31 December 2020 until 1 February
See MoreTransfer Pricing Brief: January 2021
AustraliaFinancial transactions-Restriction on interest deduction: 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
See MoreIreland: Finance Minister publishes a feedback on ATAD interest limitation rule
On 23 December 2020, the Finance Department published feedback statement, which considers the final ATAD measure, an Interest Limitation Rule, which will also be implemented in Finance Bill 2021. In Ireland, the general anti-abuse rule (GAAR) met
See MoreMalta: CFR releases guideline on DAC6 reporting
On 4 January 2021, the Maltese Commissioner for Revenue (CFR) has released 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 guidelines
See MoreColombia issues a decree on the tax return and TP documentation deadline
On 17 December 2020, the Colombian Ministry of Finance and Public Credit has issued Decree 1680 specifying the deadlines for filing and payment of the tax return (declaration) in 2021 and the deadline for transfer pricing (TP) documentation,
See MoreSri Lanka: IRD publishes CbC reporting and notification due dates
On 22 December 2020, the Inland Revenue Department (IRD) of Sri Lanka has published a notice related to the filing of Country-by-Country (CbC) reports and notifications. According to the notice, the ultimate parent company or its
See MoreOman extends CbC notification deadline
In reference to the Decision No. 79/2020 on Rules for Country-By-Country Reporting that specified designated persons (MNEs), information to be provided, retention periods, and the procedures to be followed in this regard; and after considering that
See MoreThailand extends deadline for e-Filing
On 15 December 2020, the Thai Revenue Department has published a Notice declaring an extension of the 8-day grace period for electronic filing and payment. Generally, the Thai Revenue Department has been providing the 8-day additional time
See MoreTaiwan: MOF amends transfer pricing provisions for profit-seeking enterprises
On 28 December 2020, Taiwan’s Ministry of Finance (MOF) has announced amendments to certain transfer pricing provisions based on chapter 8 to 10 of the OECD Transfer Pricing Guidelines for profit-seeking enterprises. The key amendments are
See MorePhilippines: BIR issues guidance on TP reporting and documentation requirements
On 18 December 2020, the Bureau of Internal Revenue (BIR) published a Revenue Regulations (RR) No. 34-2020, which replaces the previous Revenue Regulations (RR) No. 19-2020, its clarifying Revenue Memorandum Circular No. 76-2020, and other relevant
See MoreFrance: Government publishes Finance Law for 2021
On 30 December 2020, the Government Officially published Finance Law for the year 2021. On 17 December 2020, the French Parliament approved the Finance Bill for 2021. The Act includes: Corporate Income Tax In the context of the Covid-19
See MoreIndia: Direct Tax highlights for 2020
By Sachin Garg, Partner- Direct Taxation, Nangia Andersen LLP Sachin.garg@nangia-andersen.com+91 93502 93097 The year 2020 has already become an unforgettable year to the unprecedented global pandemic across the world, nation-wide
See MoreMorocco: Finance Law 2021
On 18 December 2020, Morocco's Ministry of Finance has published the Finance Law for 2021 in the Official Gazette. The measures of the Finance Law generally apply from 1 January 2021. Key measures are summarized as follows: Social
See MorePoland launches public consultation on draft guidance regarding the application of TP Method
On 18 December 2020, Poland’s Ministry of Finance has launched a public consultation on draft tax guidance regarding clarifications on transfer pricing regarding the comparable uncontrolled price method. The transfer pricing provisions
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