Dominican Republic: DGII declares public consultation to amend TP rules
On 1 March 2021, the Directorate General of Internal Revenue (DGII) made an announcement of launching a public consultation on the draft modification of articles 5, 7, 10 and 18 of the transfer pricing (TP) regulation, established by means of the
See MoreIreland: Revenue publishes an eBrief to update DAC6 reporting guidance
On 1 March 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 to update the DAC6
See MoreIreland: Revenue issues an eBrief to announce updated TP guidance
On 24 February 2021, the Irish Revenue issued eBrief No. 37/21 regarding updated guidance on transfer pricing. On the similar day, the Revenue also published a Tax and Duty Manual-Part 35A-01-01, providing updated guidance on the operation of the
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 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 MoreHungary: 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 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 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 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 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 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.
See MoreSweden applies the so-called “Sunday rule” for DAC6 reporting deadlines
Recently, the Swedish Tax Agency has updated guidance on reportable arrangements (DAC6) reporting deadlines. The Tax Agency confirms that the so-called “Sunday rule” applies for DAC6 reporting deadlines. If the reporting deadline falls on a
See MoreSouth Africa: Government Officially publishes 2020 Tax Amendment Acts
On 20 January 2021, the Treasury Department Officially published the 2020 Tax Amendment Acts. The following Amendment Acts were promulgated: Rates and Monetary Amounts and Amendment of Revenue Laws Act 22 of 2020.Taxation Laws Amendment Act 23
See MoreMalta: CFR notifies about DAC6 reporting deadline
On 29 January 2021, the Maltese Commissioner for Revenue (CFR) has notified that with respect to cross-border arrangements where the trigger point for reporting took place between 1 July 2020 and 31 December 2020, the deadline for reporting must
See MoreAustralia amends the definition of SGE
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 measures. The SGE concept was introduced by the
See MoreSpain defers due dates of digital services tax and financial transaction tax
The Spanish Tax Agency has issued a notice announcing a deferral of the initial deadlines for the new Financial Transactions Tax (FTT) and Digital Services Tax (DST), which both entered into force on 16 January 2020. The deadline deferrals
See MoreParaguay 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 MoreIreland: President signs the Finance Bill 2020 into Law
On 19 December 2020, the President signed the Finance Bill 2020 into Law, which underpins the Government’s support for the economy in the face of Covid-19 pandemic and the ongoing threat of a no-deal Brexit. The Finance Act 2020 provisions
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