Portugal publishes new transfer pricing Legislation
On 26 November 2021, the Portuguese Tax Administration (PTA) published Order No. 268/2021, which replaces Regulation No. 1446-C / 2001 of December 21, 2001. The new regulation revises the rules for implementing the arm's length principle under
See MoreJordan issues Executive Instructions on new TP rules for MNE groups
On 16 September 2021, the Hashemite Kingdom of Jordan has published Executive Instructions No. 3 of 2021 regarding new transfer pricing (TP) rules for MNE groups. Jordan has published Regulation No. 40 of 2021 On 7 June 2021 which introduces
See MoreGermany: MOF issues new guidance on transfer pricing
On 14 July 2021, the German Ministry of Finance (MoF) published a decree providing updated administrative principles on transfer Pricing. The new decree replaces several decrees that were passed in the past at transfer prices, in particular the
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 MoreParaguay releases sixth TP method for commodity transactions
On 16 April 2021, the tax authority of Paraguay has published General Resolution No. 86 with effect from 17 April 2021, regarding the application of the special transfer pricing (TP) rules, related to the sixth method, for certain commodity
See MoreDominican Republic: DGII issues a Decree to amend TP rules
On 21 April 2021, the Directorate General of Internal Revenue (DGII) published Decree 256-21, which makes modification on articles 5, 7, 10 and 18 of the transfer pricing (TP) regulation, established by means of the Decree no. 78-14, of March 14,
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 MoreParaguay introduces new guidance on TP law
On 30 December 2020, the tax authority of Paraguay issued Decree 4644/2020, providing further guidance on the technical aspects of Paraguay’s transfer pricing (TP) provisions included in Law 6380. Law No. 6,380/2019 modernized the Paraguayan
See MorePoland launches public consultation on draft guidance regarding the application of TP Method
On 18 December 2020, Poland’s Ministry of Finance has launched a public consultation on draft tax guidance regarding clarifications on transfer pricing regarding the comparable uncontrolled price method. The transfer pricing provisions
See MoreOECD publishes public comments on proposals on taxation of the digital economy
On 16 December 2020 the OECD published comments received on the Blueprints outlining the remaining issues involved in finalising the work on Pillar One and Pillar Two of the proposals on tax challenges arising from the digitalisation of the
See MoreTurkey publishes transfer pricing General Communiqué No. 4
On 1 September 2020, the Turkish Revenue Administration has published transfer pricing General Communiqué No. 4 on disguised profit distribution in the Official Gazette No. 31231. The Communiqué explains information regarding new transfer pricing
See MoreColombia: DIAN starts a new system for the registration of commodity agreements
On 3 August 2020, the Colombian tax authority (DIAN) has launched an online system for registering commodities agreements for the purposes of carrying out commodity operations with related parties from abroad or in the Free Trade Zone or third
See MoreTanzania: Revenue Authority issues new transfer pricing guideline 2020
On 1 July 2020, the Tanzania Revenue Tax Authority issued the Transfer Pricing Guidelines 2020, which provides the instructions of how to apply Transfer Pricing Regulations, 2018. It covers the guidance on the arm’s length principle, functional
See MoreEcuador: The Internal Income Service amends prior Resolutions regarding transfer pricing
On 1 July 2020, the Government published Resolution No. NAC-DGERCGC20-00000046 of 1 July 2020, which amends the calculation of profit level indicators. According to amendments, it is provided that taxpayers must use the last financial information
See MoreOECD: Tax Talk Summarises Ongoing Tax Projects
A Tax Talk held by the OECD on 4 May 2020 summarised the position on the current tax work in connection with the Covid-19 crisis and on the base erosion and profit shifting (BEPS) project. Tax measures in the Covid-19 crisis The Forum on Tax
See MoreTurkey: Revenue Administration issues decree on transfer pricing documentation
On 25 February 2020, the Turkish Revenue Administration has published Presidential Decree No. 2151 in the official gazette, which amends transfer pricing documentation rules. The decree aims to set out OECD’s Base Erosion and Profit Shifting
See MoreGermany: Federal Ministry of Finance publishes a draft law with significant changes to TP rules
On 10 December 2019, Germany published a draft law implementing EU anti-tax avoidance directive. The Draft Law includes significant changes to the German transfer pricing rules. The following proposed changes have been taken place under the
See MoreRussia enacts legislative changes on Transfer Pricing and MAP
On 29 September 2019, the Russian Government signed a Law no. 325-FZ (Amendments to the Tax Code of the Russian Federation) and published in the Official Gazette. The main amendments relating to transfer pricing are as
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