Singapore issues advance ruling summary on determination of related parties
On 4 January 2021, the tax Authority of Singapore has published Advance Ruling Summary No. 1/2021, regarding the determination of related parties for transfer pricing (TP) purposes in cases involving a joint venture without majority control.
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 MoreFrance: Tax Authority announces a webpage regarding DAC6 reporting
Recently, the Tax Authority has announced a webpage entitled “Déclaration des dispositifs transfrontières”, which contains french specifications for the reporting of cross-border schemes under DAC6 and the Mandatory Disclosure Rules (MDR).
See MoreUkraine: Parliament accepts changes to recently implemented BEPS legislation
On 17 December 2020, the Ukrainian Parliament has accepted a tax reform bill, which contains important changes to recently implemented BEPS legislation. The following important changes were introduced related to recently implemented BEPS and other
See MoreCzech Republic: Tax Authority publishes Q&A regarding DAC6 obligations
On 9 December 2020, the General Financial Directorate published a document containing most frequently asked questions and answers in relation to the mandatory disclosure of reportable cross-border arrangements (DAC6). According to the document, the
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 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 MoreMexico issues general tax rules on Mandatory Disclosure Rules (MDR)
On 18 November 2020, the Mexican Tax Administration (SAT) has issued general tax rules (GTR) for 2020. The GTR includes a new ‘chapter’ related to the mandatory reporting requirements for certain transactions. Mandatory Disclosure Rules (MDR)
See MoreSri Lanka: TP documentation requirement for domestic controlled transactions
According to the notice of 25 November 2020, under the Regulation 1 of the TP Gazette, transfer pricing regulations inter alia, are applicable to the local transactions made between associated enterprises (AE) as referred to in section 77 of the
See MoreFrance: Tax authorities update guidelines regarding DAC6 reporting obligations
On 25 November 2020, the tax authorities published updated guidance regarding reporting rules applicable to intermediaries as regards cross-border arrangements under the provisions of Council Directive (EU) 2018/822 (DAC6) and it provides
See MoreBelgium: Guidance on the technological requirements of DAC6
On 23 November 2020, the Belgian tax authorities issued guidance on the technological requirements of DAC6 and the mandatory disclosure and reporting of certain cross-border arrangements. The guidance comprises a user guide describing the
See MoreMalta: CFR issues DAC6 XML Schema and user guide
On 16 November 2020, the Maltese Commissioner for Revenue (CFR) has issued the DAC6 XML Schema (to be used for filing information in relation to reportable cross-border arrangements) and the DAC6 XML Schema user
See MoreItaly publishes Decree on procedures for DAC6 Reporting
On 20 November 2020, the Italian Ministry of Finance issued a Decree containing technical rules and procedures for the implementation of the DAC6 reporting requirements introduced by Legislative Decree No. 100 of 30 July 2020. In accordance
See MoreIreland: Revenue publishes eBrief regarding DAC6 reporting update
On 3 November 2020, the Irish Revenue published an eBrief No. 200/20, which provides EU mandatory disclosure of reportable cross-border arrangements. On the similar day, the Revenue also published a Tax and Duty Manual, providing general
See MoreAustria: Finance Ministry publishes final guide regarding DAC6 reporting obligations
On 21 October 2020, the Finance Ministry published final guidance regarding the reporting requirement of cross border arrangements (DAC6). This final guide covers the definition of terms, reportable arrangements, hallmarks and main benefit test,
See MoreLuxembourg: Tax Administration issues update guidance on DAC6 reporting
On 14 October 2020, the Luxembourg Tax Administration has issued updated guidelines concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) as per Council Directive (EU) 2018/822 of 25 May 2018. DAC6 is effective
See MoreMalta: CFR extends DAC6 notification deadline for non-disclosing intermediaries
On 18 September 2020, the Maltese Commissioner for Revenue (CFR) has notified that due to the deferral of the reporting deadlines as a result of the COVID-19 pandemic, the period allowed for notification by non-disclosing intermediaries is being
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