Singapore: TP guidelines for centralized activities in MNE groups
On 19 Mar 2021, the Inland Revenue Authority of Singapore (IRAS) issued an e-Tax Guide “Transfer Pricing Guidelines Special Topic - Centralized Activities in Multinational Enterprise Groups”. The e-Tax guide discusses the economic value
See MoreCanada: Finance Minister presents Budget 2021
On 19 April 2021, the Finance Minister, Chrystia Freeland, presented Budget 2021, which includes important business tax measures, digital service taxes, limitation of interest deduction, hybrid mismatch arrangements, transfer price cases, mandatory
See MoreSpain: Tax agency approves forms regarding DAC6 reporting
On 13 April 2021, the Spanish tax agency has published an Order HAC / 342/2021 regarding the approval of forms for reporting of information on cross-border arrangements under DAC6. Accordingly, Model 234, which will be presented in relation to
See MoreSpain gazettes decree amending regulation on DAC6 reporting
On 7 April 2021, the Spanish Official Gazette published the Royal Decree No. 243/2021, amending the general regulation on the mandatory automatic exchange of financial account information (AEOI) in relation to reportable cross-border arrangements
See MoreGermany: Ministry of Finance releases DAC6 reporting guidelines
On 29 March 2021, the German Ministry of Finance has published the final decree regarding the application of the mandatory disclosure rules relating to certain cross-border tax arrangements as per Council Directive (EU) 2018/822 of 25 May 2018.
See MoreCyprus gazettes the law to implement mandatory disclosure rules
On 31 March 2021, the Cyprus official gazette published the law (Ν. 41(Ι)/2021, the Law) amending the Law on Administrative Cooperation in the field of Taxation (Law N. 205(I)/2012). The Law transposed the EU Council Directive 2011/16 referred to
See MoreUK: Consultation on Transfer Pricing Documentation
On 23 March 2021 the UK government published a consultation paper on transfer pricing documentation. The closing date for comments is 1 June 2021. Following the final report on Action 13 of the OECD Action Plan on base erosion and profit
See MoreDominican 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.
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