Turkey: Parliament members submit a new Tax Bill to the Parliament

October 07, 2021

On 1 October 2021, Turkish Parliament members have submitted a new Tax Bill to the Parliament which includes tax filing periods, tax exemptions, and incentives. The key corporate tax measures of the Bill are: In the reduced corporate tax

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Thailand extends tax refunds deadline in MAP cases

September 20, 2021

On 23 August 2021, the Ministry of Finance of Thailand has issued a notification that provides an extension of the deadline to request a corporate or individual income tax refund for certain eligible persons whose standard time to request a tax

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Finland: Ministry of Finance issues budget proposal for 2022

September 16, 2021

On 9 September 2021, the Ministry of Finance of Finland has released the government’s budget proposal for 2022 including following tax measures. Companies may make an extra deduction of 150% in their taxation for 2022-2027 for research and

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Germany publishes Guidance on MAP and arbitration procedures

September 01, 2021

On 27 August 2021, the Federal Ministry of Finance published guidance on mutual agreement (MAP) and arbitration procedures. The guide explains how to initiate procedures, how to carry out procedures, how to execute agreements, etc. The guidance

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Finland: MOF launches public consultation on transfer pricing adjustment

August 29, 2021

On 21 August 2021, the Finland’s Ministry of Finance has launched a public consultation on draft bill concerning the revision of the Finnish transfer pricing adjustment provision. The draft law includes measures that: 1) align the

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India: CBDT notifies a formula to adjust MAT relief for secondary adjustment and APA

August 25, 2021

On 10 August 2021, the Central Board of Direct Taxes (CBDT) has published Notification No. 92/2021, which contains a new rule for calculating tax relief in the event of an increase in book profit as a result of adjustments to Advance Pricing

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Germany: MoF publishes new administrative principles on TP

August 02, 2021

On 14 July 2021, the Ministry of Finance (MoF) has issued new administrative principles on transfer pricing. The administrative principles include extensive references to the OECD Transfer Pricing Guidelines and provide further details clarifying

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Canada: CRA replaces and abolishes a Circular regarding MAP

June 29, 2021

On 1 June 2021, the Canada Revenue Agency (CRA) published Information Circular IC71-17R6, which replaces and cancels Information Circular 71-17R5 dated January 1, 2005. This Circular describes several changes related to MAP. MAP filing

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Taiwan: MOF issues Decree on cross-border bilateral, multilateral APAs under MAP

June 28, 2021

On 24 June 2021, the Ministry of Finance issued a Decree which stipulates that when tax collection authorities negotiate cross-border bilateral or multilateral advance pricing arrangements (APAs) (hereinafter referred to as "BAPAs") with the

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Morocco publishes guidance on mutual agreement procedure

June 24, 2021

The Ministry of Finance (MoF) of Morocco has published guidance on the mutual agreement procedure (MAP), which provides a dispute resolution procedure to resolve tax treaty related disputes. MAP is designed to relieve double taxation, typically

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Spain publishes a decree amending Mutual Agreement Procedure (MAP)

June 15, 2021

On 8 June 2021, the Spanish government has published a Royal Decree 399/2021 which amends the Regulation on Mutual Agreement Procedures (MAP) as approved by Royal Decree 1794/2008. The decree implements three packages of initiatives to enhance

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UAE publishes guidance on mutual agreement procedure

June 15, 2021

The Ministry of Finance (MoF) of the United Arab Emirates (UAE) has published guidance on the mutual agreement procedure (MAP), which provides a dispute resolution procedure to resolve tax treaty related disputes. MAP is designed to relieve

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Jordan introduces transfer pricing rules for MNE groups

June 14, 2021

On 7 June 2021, the Hashemite Kingdom of Jordan has published Regulation No. 40 of 2021 in the Official Gazette. The Regulation has introduced transfer pricing rules for multinational entity (MNE) groups with effect from 7 July 2021. The Regulation

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Singapore updates GST Guide on Transfer Pricing Adjustments

June 05, 2021

On 1 June 2021, the Inland Revenue Authority of Singapore (IRAS) has published second edition of e-Tax Guide GST: Transfer Pricing Adjustments. The e-Tax guide explains the GST treatment for adjustments on the transfer prices of transactions

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OECD: Peer review reports on making tax dispute resolution more effective

May 25, 2021

On 25 May 2021 the OECD released a further batch of eight Stage Two peer review reports in relation to making dispute resolution mechanisms more effective under BEPS Action 14. The minimum standard under BEPS action 14 is concerned with

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Malta enacts Budget Measures Implementation Act 2021

April 28, 2021

On 16 April 2021, Malta has published and enacted Act to implement Budget Measures for the Financial Year 2021and other administrative measures (Act No. XVIII of 2021). The budget measures were announced in October 2020 which came into force on

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OECD: Peer review reports under BEPS Action 14

April 17, 2021

On 15 April 2021 the OECD released peer review assessments under Action 14 of the project on base erosion and profit shifting (BEPS) which aims to make dispute resolution mechanisms more effective. These stage two monitoring reports relate to

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Poland: MOF publishes tax explanations on transfer pricing adjustment

April 12, 2021

On 2 April 2021, the Polish Ministry of Finance has published tax clarifications on transfer pricing regarding the adjustment of transfer prices within the meaning of Art. 11e of the CIT Act (Article 23q of the PIT Act), in relation to the

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