Transfer Pricing Brief: August 2022
Cyprus Scope of transfer pricing rules: On 30 June 2022, the Cyprus House of Representatives enacted detailed transfer pricing legislation amending the Cyprus Income Tax Law (ITL) and the issuance of Regulations. The amendment includes the
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Transfer Pricing Brief: July 2022
Dominican Republic CbC reporting requirement-Threshold: On 22 June 2022, the Directorate General of Internal Revenue (DGII) published a Notice (No. 18-22) clarifying CbC for Multinational Enterprises (MNEs). If the group reports and is
See MoreTransfer Pricing Brief: June 2022
ArgentinaFiling deadlines: On 28 April 2022, the Federal Public Revenue Administration (AFIP) published General Resolution 5189/2022 of 28 April 2022, which extends the submission deadline of corporate tax return to between 23 and 26 May 2022.See
See MoreTransfer Pricing Brief: May 2022
BulgariaCompliance with BEPS standards: On 15 April 2022, Parliament is considering a bill to ratify the Multilateral Convention Implementing Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (MLI).See the story in
See MoreTransfer Pricing Brief: March 2022
DenmarkDocumentation-Timing and deadlines: On 31 January 2022, the Danish Ministry of Finance issued updated guidance regarding amendments to the transfer pricing rules requiring the submission of the transfer pricing documentation within 60 days
See MoreTransfer Pricing Brief: February 2022
ColombiaDocumentation/CbC reporting/Master file/Local file: On 20 December 2021, the Colombian Ministry of Finance and Public Credit has issued Decree 1778 specifying the deadlines for transfer pricing (TP) documentation, including local/master
See MoreTransfer Pricing Brief: January 2022
AustraliaSpecial rules for hybrid instruments or entities: On 16 December 2021, the Australian Taxation Office (ATO) issued Practical Compliance Guideline 2021/5 on imported hybrid mismatch rule relating to a practical administrative approach to
See MoreTransfer Pricing Brief: December 2021
AustraliaCbC reporting requirement-Deadlines: On 18 November 2021, the Australian Taxation Office (ATO) announced that country-by-country (CbC) reporting entities that have a CbC reporting obligation due by 31 December 2021 will now have until 4
See MoreTransfer Pricing Brief: November 2021
AustriaDocumentation-Requirement: On 7 October 2021, the Austrian Ministry of Finance published the updated Austrian Transfer Pricing Guidelines (Austrian Guidelines) 2021. The guideline provided guidance for those companies which fall under the
See MoreTransfer Pricing Brief: October 2021
BotswanaDocumentation-Thresholds: On 1 September 2021, the General Commissioner published a ruling which sets the threshold for the preparation and submission of transfer pricing documentation. Accordingly, the obligation to prepare and submit
See MoreTransfer Pricing Brief: September 2021
ChinaAPAs-Unilateral: On 26 July 2021, the State Administration of Taxation (SAT) issued Announcement No. 24 (2021) that finalizes a simplified procedure for unilateral advance pricing arrangements (APAs), which will come into effect on 1 September
See MoreTransfer Pricing Brief: August 2021
AustraliaLocal file-General rule: The Australian Taxation Office (ATO) has provided 31 December 2020 early balancing entities additional time until 30 August 2021 to lodge Part A of their 2021 local file if they indicate in their tax return they
See MoreTransfer Pricing Brief: July 2021
ArgentinaTransfer pricing information return: On 18 June 2021, the Federal Administration of Public Revenues (AFIP) officially published General Resolution 5010/2021, which extends the deadline for filing transfer pricing reports and related forms
See MoreTransfer Pricing Brief: June 2021
ArgentinaTransfer pricing information return: On 30 April 2021, the Federal Administration of Public Revenue (AFIP) made an announcement that it will exceptionally extend the due date of submitting transfer pricing study and Form F. 2668 from June
See MoreTransfer Pricing Brief: May 2021
AlgeriaFiling deadlines: The Directorate General of Taxes has recently issued a communiqué, which provides extension of filing deadline of annual tax returns (including balance sheet and appendices) 2020 until 30 June 2021 for all companies.See
See MoreTransfer Pricing Brief: April 2021
ChileCompliance with BEPS standards: On 1 March 2021, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting
See MoreTransfer Pricing Brief: March 2021
AzerbaijanCbC reporting requirement-General rule: Recently, Azerbaijan has introduced CbC reporting requirements and notification requirements for multinational entity groups (MNE groups) headquartered or operating in Azerbaijan. The CbC reporting
See MoreTransfer Pricing Brief: February 2021
AustraliaScope of transfer pricing rules: Australian Taxation Office (ATO) expanded the definition of “significant global entity (SGE)”. The SGE concept determines whether an entity is subject to a number of tax integrity and reporting
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