Turkey publishes transfer pricing General Communiqué No. 4
On 1 September 2020, the Turkish Revenue Administration has published transfer pricing General Communiqué No. 4 on disguised profit distribution in the Official Gazette No. 31231. The Communiqué explains information regarding new transfer pricing
See MorePanama: Special tax regime for multinational companies
On 31 August 2020, Mr. Laurentino Cortizo, the president of Panama signed Law No. 159, introducing a new tax regime designed to encourage multinationals to establish and operate manufacturing services in Panama. The new law (EMMA) looking
See MoreNew Zealand: Inland Revenue releases guidance on transfer pricing amid COVID-19
Recently, New Zealand’s Inland (IR) Revenue has released guidance regarding practice issues for transfer pricing due to the COVID-19 pandemic. The COVID-19 pandemic has created an impact on specific sectors and businesses substantially. The
See MoreItaly finalizes legislative decree for the implementation of DAC6
On 30 July, Italy has published Legislative Decree No. 100 in the Official Gazette as approved by the Council of Ministers for the implementation of the required reporting and exchange of information on cross-border arrangements as per
See MoreCzech Republic: Financial Administration confirms delay of DAC6 reporting obligations
On 19 August 2020, the Financial Administration published an announcement about the Official publication of a Law 343/2020 of 14 August 2020 regarding the transposing the DAC6 cross-border arrangement reporting obligations. This Law will take enter
See MoreUS: North Carolina announces voluntary corporate transfer pricing resolution initiative
On 30 July 2020, the North Carolina Department of Revenue announced that it is implementing a voluntary initiative to expedite the resolution of corporate intercompany pricing issues. The purpose of this initiative is to fairly and consistently
See MoreLithuania defers MDR reporting deadlines for six months
On 30 July 2020, the Lithuanian State Tax Inspectorate released amendments to the Mandatory Disclosure Regime (MDR) rules to introduce a six-month postponement of the European Union (EU) Directive on Mandatory Disclosure and Exchange of
See MoreSouth Africa: National Treasury publishes draft 2020 Tax Law Amendment Bills
On 31 July 2020, the National Treasury published the 2020 Draft Taxation Laws Amendment Bill, which includes a proposed change to the definition of “affected transaction” for transfer pricing purposes. The proposed amended definition would be
See MoreFrance: Government publishes third amending Finance Law for 2020
On 31 July 2020, the Government Officially published Law No. 2020-935, which was basically third amending Finance (Budget) Law for 2020. The Law includes the following changes: Deferral of DAC6 reporting obligations According to the Law, the
See MoreBulgaria: Parliament publishes a Law to extend the deadline for DAC6
On 4 August 2020, the National Assembly Officially published a Law to extend the due date of cross border arrangements (DAC6). According to the Law, the deadline to report arrangements, which was implemented between 25 June 2018 and 30 June 2020,
See MoreHungary releases guideline on DAC6 reporting
On July 20, 2020, the Hungarian National Tax and Customs Administration published guidelines on the new reporting obligation for cross-border tax planning agreements (DAC6). The guidelines provide an overview of the reporting legislation, the
See MoreMalta issues legal notice regarding deferral of DAC6
On 31 July 2020, Malta’s Commissioner for Revenue has issued Legal Notice 315 of 2020, which enacts the deferral of reporting on EU cross-border arrangements (DAC6) due to COVID-19 pandemic. All reporting and data exchange deadlines in 2020, the
See MoreHungary defers MDR reporting deadlines for six months
On 14 July 2020, the Hungarian Government issued a new regulation, deferring the reporting deadlines by six months. The deadline for the reporting of arrangements in the period between 25 June 2018 and 30 June 2020 will be 28 February
See MoreDAC6 Updates: Optional deferral of DAC6 reporting deadlines
On 24 June 2020, the European Council reached agreement on an optional 6-month postponement to the reporting deadlines for relevant taxpayers under EU Directive 2018/822 (DAC6), and a delay to the exchange of information under
See MoreFrance: Parliament approves the postponement of DAC6 reporting deadlines
Due to coronavirus outbreak, the European Commission has recently agreed to delay the entry into force of certain European Union (EU) taxation measures. Among these is the delay of Council Directive 2018/822, commonly known as the Directive on
See MoreAustralia updates transfer pricing legislation in accordance with OECD guidelines
Australia's transfer pricing legislation has been updated to specify that it is to be interpreted to achieve consistency with the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines for Multinational
See MoreCyprus postpones reporting cross-border arrangements (DAC6)
On 27 July 2020, the tax authority of Cyprus issued a notice declaring an initial deferral of DAC6 reporting on cross-border arrangements. The submission of DAC6 information in Cyprus is extended as information on reportable arrangements
See MoreTanzania: Revenue Authority issues new transfer pricing guideline 2020
On 1 July 2020, the Tanzania Revenue Tax Authority issued the Transfer Pricing Guidelines 2020, which provides the instructions of how to apply Transfer Pricing Regulations, 2018. It covers the guidance on the arm’s length principle, functional
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