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 Decree no. 78-14, of March 14, 2014, which aims to repeal and replace articles 5,7,10 and 18 of the aforementioned Decree no. 78-14. That means this proposed to make changes on comparability analysis and applicable TP methods in accordance with OECD guidelines. Also, it revised requirements for the Informative Return for Transactions with Related Parties (DIOR) and new rules for submitting Country-by-Country (CbC) reports from the 2021 reporting fiscal year. Again, the new Decree proposed to declare the deadline for submitting master file and local file according in line with the OECD guidelines.
The public consultation lasts for twenty-five business days, beginning on Monday, 1 March 2021, until 5 April 2021.
