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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Paraguay releases sixth TP method for commodity transactions

May 10, 2021

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

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Dominican Republic: DGII issues a Decree to amend TP rules

April 28, 2021

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,

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Dominican Republic: DGII declares public consultation to amend TP rules

March 15, 2021

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

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Paraguay introduces new guidance on TP law

January 26, 2021

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

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Poland launches public consultation on draft guidance regarding the application of TP Method

December 24, 2020

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

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OECD publishes public comments on proposals on taxation of the digital economy

December 23, 2020

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

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Turkey publishes transfer pricing General Communiqué No. 4

September 24, 2020

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

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Colombia: DIAN starts a new system for the registration of commodity agreements

August 12, 2020

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

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Tanzania: Revenue Authority issues new transfer pricing guideline 2020

July 30, 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

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Ecuador: The Internal Income Service amends prior Resolutions regarding transfer pricing

July 10, 2020

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

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OECD: Tax Talk Summarises Ongoing Tax Projects

May 11, 2020

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

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Turkey: Revenue Administration issues decree on transfer pricing documentation

February 27, 2020

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

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Germany: Federal Ministry of Finance publishes a draft law with significant changes to TP rules

December 25, 2019

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

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Russia enacts legislative changes on Transfer Pricing and MAP

October 15, 2019

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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Luxembourg: EU General Court upholds EC Commission’s decision in Fiat case

September 30, 2019

On 24 September 2019, the EU General Court upheld the Commission’s decision that Fiat received unlawful State aid from Luxembourg, and at the same time cancelled the decision which had found the same with respect to Starbucks in the

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Portugal publishes changes to various Tax Codes

September 23, 2019

On 18 September 2019, the Portuguese Government officially published the Law no.119/2019. The new law has changed the following provisions: Corporate income tax: The procedure whereby non-resident companies may waive all or part of the

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Russia: FTS clarifies the application of CUP method

September 21, 2019

On 2 September 2019, the Federal Tax Service (FTS) of Russia published a Letter No. CA-4-7/17555, about the review of litigation regarding tax control in the field of transfer pricing. For tax purposes, the FTS noted that the courts recognize the

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