Canada: CRA replaces and abolishes a Circular regarding MAP
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
See MoreTaiwan: MOF issues Decree on cross-border bilateral, multilateral APAs under MAP
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
See MoreMorocco publishes guidance on mutual agreement procedure
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
See MoreSpain publishes a decree amending Mutual Agreement Procedure (MAP)
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
See MoreUAE publishes guidance on mutual agreement procedure
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
See MoreJordan introduces transfer pricing rules for MNE groups
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
See MoreSingapore updates GST Guide on Transfer Pricing Adjustments
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
See MoreOECD: Peer review reports on making tax dispute resolution more effective
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
See MoreMalta enacts Budget Measures Implementation Act 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
See MoreOECD: Peer review reports under BEPS Action 14
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
See MorePoland: MOF publishes tax explanations on transfer pricing adjustment
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
See MoreLuxembourg: Tax Authorities issues circular on updated MAP guidance
On 11 March 2021, the Luxembourg Tax Authorities has issued Circular L.G. - Conv. D.I. n° 60 regarding the updated mutual agreement procedure (MAP) guidance. The Circular replaces previous Circular L.G. Conv. D.I. No. 60 of 28 August 2017. The
See MoreSwitzerland: Review on international financial and tax matters of 2020
Switzerland’s Secretariat for International Finance (SIF) has published its annual review on international financial and tax matters for 2020. With respect to tax-related matters in particular, the review includes the following: Taxing
See MoreItaly: New regulations for mutual agreement procedure
On 16 December 2020, the Italian tax authority published regulations to implement new tax dispute resolution mechanisms and mutual agreement procedure (MAP). The Measures to allow taxpayers to contact the tax authorities in Italy to discuss the
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US and Mexico renew competent authority agreement on Maquiladoras
On 16 November 2020, the Internal Revenue Service (IRS) announced that IRS and Mexico’s Servicio de Administración Tributaria (“SAT”) have agreed to renew the Qualified Maquiladora Approach Agreement (“QMA”), a coordination
See MoreSwitzerland: Federal Council adopts dispatch on Federal Act on implementation of international tax agreements
On 4 November 2020, the Swiss Federal Council adopted the dispatch on the Federal Act on the implementation of international tax agreements. With this proposal, the Federal Council is adapting the existing law to the changes made to international
See MoreUS: IRS updates parameters for APA and MAP
On 28 October 2020, the US Internal Revenue Service (IRS) published that it is updating parameters that the Advance Pricing and Mutual Agreement program (APMA), a representative office of the U.S. competent authority, will follow in implementing
See MoreSouth Korea: NTS releases updated MAP guidance
On 20 October 2020, South Korea's National Tax Service (NTS) has released updated Mutual Agreement Procedure (MAP) guidance on the official website. The guidance prescribes the following key areas: Overview of a Mutual Agreement Procedure
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