Brazil and OECD present outline of new transfer pricing rules
On 12 April 2022 an event was held to present the outline of the new transfer pricing rules drafted by Brazil following a consultation process with the OECD. After Brazil had expressed the intention to become a full OECD member, Brazil and the
See MoreCyprus: Tax department publishes FAQs on DAC6 reporting
On 8 April 2022, the Tax Department of Cyprus has posted online Frequently Asked Questions (FAQs) regarding reportable cross-border tax arrangements (DAC6). The FAQs are currently available in Greek language and covered following
See MoreOECD: Strengthening Transfer Pricing Capacity in Mongolia
On 8 April 2022 the OECD published a tax and development case study entitled Tackling Multinational Tax Avoidance in Mongolia. In 2019 the OECD and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF)
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Ireland: Revenue issues an eBrief regarding DAC6
On 1 April 2022, the Revenue published an eBrief No. 078/22, which updates a manual regarding mandatory disclosure of reportable cross-border arrangements (DAC6). This was introduced by Finance Act 2021 and to provide additional guidance on the
See MoreUS: Treasury Department releases tax proposals from Budget 2023
On 28 March 2022, the Treasury Department of United States published details of tax proposals in the administration’s budget recommendations for FY 2023 in the “GreenBook.” The Greenbook describes following tax measures related to corporate
See MoreRussia raises the threshold for controlled transactions
On 22 March 2022, the Russian Parliament amended the criteria for controlled transactions for transfer pricing purposes. Accordingly, the general transaction threshold for transactions to be considered controlled transactions will be raised from
See MoreNigeria: FIRS posts digital FAQs regarding transfer pricing
On 15 March 2022, the Federal Inland Revenue Service (FIRS) made a post of frequently asked questions and answers (FAQs) related to transfer pricing (TP) through online. This includes applicable regulations and their scope; documentation
See MoreKazakhstan: Government invites public comments regarding transfer pricing amendments
On 16 March 2022, the State Revenue Committee announced that they opened a public consultation on a draft bill to amend transfer pricing rules. The deadline for this public comments is 8 April 2022. The draft Bill contained the following measures
See MoreGreece: AADE issues a Circular to provide guidance on CFC rules
On 23 February 2022, the Greek Public Revenue Authority (AADE) published Circular E. 2018 of 23 February 2022, providing guidance on the application of Controlled Foreign Companies (CFC rules). This is introduced as from 1 January 2019 in line with
See MoreOECD: Updates to Transfer Pricing Country Profiles
On 28 February 2022 the OECD released updated transfer pricing country profiles for 22 countries, together with new transfer pricing profiles for six more countries. This is the third batch of updates for 2021/22. The OECD transfer pricing
See MoreOECD: Tax Report for the G20 Finance Ministers
On 18 February 2022 the OECD presented its tax report for the G20 Finance Ministers and Central Bank Governors. The main parts of the report are summarised below. Two-Pillar International Tax Package In October 2021 the OECD Inclusive
See MoreSlovenia updates the TP guidelines
On 31 January 2022, the Slovenian Ministry of Finance updated the transfer pricing (TP) guidelines. The revised guidance includes the new documentation requirements and procedures for determining income and transfer pricing, including for
See MoreLithuania publishes form for reportable cross-border arrangements
On 17 January 2022, the State Tax Inspectorate issued Order No. VA-7 of 14 January 2022, amending the rules for annual reporting on the use of reportable cross-border arrangements for DAC6. The order introduces the PRC914 notification form and
See MoreSaudi Arabia: ZATCA releases the third edition of transfer pricing guidelines
In November 2021, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) released the third edition of Transfer Pricing Guidelines in English. The first edition and second edition were released in March 2019 and May 2020 respectively. These
See MoreMalta seeks comments on draft Transfer Pricing Rules
On 22 December 2021, Malta’s Commissioner for Revenue (CFR) has published draft Transfer Pricing Rules on its website for public consultation. The consultation period will end on 28 February 2022, and the draft Transfer Pricing Rules shall come
See MoreFinland issues guidance on application of OECD guidelines for domestic TP rules
On 17 December 2021, the Finnish Tax Administration issued Guidance No. VH/5755/00.01.00/2021, on the application of OECD transfer pricing guidelines to domestic transfer pricing rules, effective from 31 December 2021. On 11 February 2020, the
See MoreOECD: Updates to Transfer Pricing Country Profiles
On 13 December 2021 the OECD released updated transfer pricing country profiles for 18 countries, together with new transfer pricing profiles for Albania, Kenya and the Maldives. The OECD has now created transfer pricing profiles for a total of 63
See MoreCyprus extends the imposition of administrative fines for DAC6 reporting
On 22 November 2021, the Cyprus Tax Department has published an announcement extending administrative fines for overdue submission of DAC6 reporting. The Tax Department informs that there will be no imposition of administrative fines for overdue
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