Transfer Pricing Brief: January 2021
AustraliaFinancial transactions-Restriction on interest deduction: On 10 December 2020, the Australian Taxation Office (ATO) issued final transfer pricing guidance on interest-free loans between related parties, in “Schedule 3 – Interest-free
See MoreTransfer Pricing Brief: December 2020
AustraliaCbC reporting requirement/Master File/Local File: The Australian Taxation Office (ATO) has issued a notice declaring a lodgment deferral until 29th January 2021 for the Local file, Master file, and Country-by-Country (CbC) report for the
See MoreTransfer Pricing Brief: November 2020
AustriaScope of transfer pricing rules: On 21 October 2020, the Finance Ministry published final guidance of cross border arrangements (DAC6) including definition of terms, reportable arrangements, hallmarks and main benefit test, deadlines for
See MoreTransfer Pricing Brief: October 2020
AustraliaSpecial rules for hybrid instruments or entities: On 3 September 2020 amending legislation to clarifying the operation of the hybrid mismatch rules (amending legislation) received royal assent. The rules designed to prevent multinational
See MoreTransfer Pricing Brief: September 2020
AustraliaFinancial transactions-Restriction on interest deduction: On 12 August 2020, the Australian Taxation Office (ATO) released its finalized practical guidance dealing with the application of the arm’s length debt test (ALDT) which applies
See MoreTransfer Pricing Brief: August 2020
ArgentinaTransfer pricing information return: On 13 July 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4759/2020 of 8 July 2020, which make slight amendments in the transitional submission deadlines of the
See MoreTransfer Pricing Brief: July 2020
ArgentinaTransfer pricing information return: On 5 June 2020, the Federal Administration of Public Revenue (AFIP) Officially published a General Resolution No. 4733 of 4 June 2020 to file affidavits under transfer pricing rules and postpones the
See MoreTransfer Pricing Brief: June 2020
ArgentinaScope of transfer pricing rules: On 15 May 2020, the Argentine tax authorities (AFIP) officially published General Resolution 4717/2020 of 14 May 2020, which governs the control of transfer prices of international transactions. The new
See MoreTransfer Pricing Brief: May 2020
ArgentinaTransfer pricing information return: On 31 March 2020, the Government officially published General Resolution 4689/2020 of 30 March 2020, which provides a further extension of deadline for the transfer pricing return forms between 18 May
See MoreTransfer Pricing Brief: April 2020
LatviaRequirement-Rule: On 5 March 2020, the Latvian Official Gazette published the law implementing the directive on the mandatory automatic exchange of information in tax matters connecting to cross-border arrangements.See the story in
See MoreTransfer Pricing Brief: March 2020
ArgentinaDocumentation-Deadlines: On 29 February 2020, Government published General Resolution 4680/2020 of 28 February 2020 extending again the deadline for the submission of transfer pricing returns between 20 and 24 April 2020 for fiscal
See MoreTransfer Pricing Brief: February 2020
FinlandRequirements-Rule: On 30 December 2019, Finnish President approved the Law 1559/2019 for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reporting requirements for cross-border tax planning arrangements.
See MoreTransfer Pricing Brief: January 2020
BrazilDispute resolution-Best practices: The OECD peer review report regarding Brazil published on 28 November 2019 notes that Brazil has concluded 35 double tax treaties all of which contain a provision relating to the mutual agreement
See MoreTransfer Pricing Brief: December 2019
DenmarkDocumentation-Deadlines: On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. Accordingly, transfer pricing documentation must be submitted to the tax authorities no later than 60 days
See MoreTransfer Pricing Brief: November 2019
SloveniaMain corporate income tax rate: Slovenia increased the corporate income tax rate from 19% to 20% with minimum tax rate 7% under the amendments of corporate income tax act. Special rules for hybrid instruments or entities: Slovenian
See MoreTransfer Pricing Brief: October 2019
GreeceCbC reporting requirement: On 17 September 2019, the Greek Public Revenue Authority (AADE) released a Circular 1341 / 09-09-2019 containing amendments regarding the submission process of CbC notifications. Under this new Circular,
See MoreTransfer Pricing Brief: September 2019
AustraliaFinancial services: On 28 August 2019, the Australian Taxation Office (ATO) published draft Practical Compliance Guideline PCG 2019/D3, which sets out the proposed compliance approach for the use of the arm’s-length debt test (ALDT)
See MoreTransfer Pricing Brief: August 2019
MalaysiaRestriction on interest deduction: On 5 July 2019, the Inland Revenue Board of Malaysia has published new guidance on restrictions to the deductibility of interest expenses. Under the rules the maximum amount of deductible interest is
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