Kazakhstan: 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
See MoreAzerbaijan modifies the Tax Code for TP, CbC Reporting, and CFC rules
On 16 November 2021, Azerbaijan has modified its Tax Code including three main changes regarding Transfer Pricing (TP), country by country (CbC) reports, and controlled foreign company (CFC) rules. The changes will be implemented from 1 January
See MoreMalta: CFR updates guideline on DAC6 reporting
On 17 November 2021, the Commissioner for Revenue (CFR) notifies that version 1.1 of the updated Guidelines on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements (DAC 6) are available for download here. Updates
See MoreUK: New Tax Regime for Asset Holding Companies
The UK budget announcements on 27 October 2021 proposed that legislation would be included in the Finance Bill 2021/22 to set up a new tax regime for qualifying asset holding companies (QAHCs). This change is part of a broader review of the UK
See MoreCyprus: Tax department publishes decree implementing regulations for DAC6
On 29 October 2021, the tax department of Cyprus published the Decree KDP 438/2021 for the implementation of the EU directives on reportable cross-border arrangements (DAC6). The decree provides guidance on the participants in a reportable
See MoreIreland adopts OECD authorized approach for TP of branches
On 21 October 2021, Minister for Finance, Paschal Donohoe TD, published the draft Finance Bill 2021, which underpins the Government’s ongoing support for the economy, particularly in response to the impact of Covid-19. It will introduce the
See MoreUN: Meetings of the Committee of Tax Experts
The UN Committee of Experts on International Cooperation in Tax Matters is holding its 23rd session as a series of virtual meetings between 19 and 28 October 2021. The issues to be covered include the following: Tax and the Sustainable
See MoreAustria releases the new transfer pricing guideline for 2021
On 7 October 2021, the Austrian Ministry of Finance published the updated Austrian Transfer Pricing Guidelines (Austrian Guidelines) 2021. The Austrian Guidelines 2021 are an essential interpretative aid for the application of the arm’s-length
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