Transfer Pricing Brief: January 2021

January 07, 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 More

Transfer Pricing Brief: December 2020

December 03, 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 More

Transfer Pricing Brief: November 2020

November 06, 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 More

Transfer Pricing Brief: October 2020

October 03, 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 More

Transfer Pricing Brief: September 2020

September 04, 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 More

Transfer Pricing Brief: August 2020

August 06, 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 More

Transfer Pricing Brief: July 2020

July 07, 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 More

Transfer Pricing Brief: June 2020

June 02, 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 More

Transfer Pricing Brief: May 2020

May 07, 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 More

Transfer Pricing Brief: April 2020

April 07, 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 More

Transfer Pricing Brief: March 2020

March 08, 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 More

Transfer Pricing Brief: February 2020

February 09, 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 More

Transfer Pricing Brief: January 2020

January 09, 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 More

Transfer Pricing Brief: December 2019

December 10, 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 More

Transfer Pricing Brief: November 2019

November 06, 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 More

Transfer Pricing Brief: October 2019

October 07, 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 More

Transfer Pricing Brief: September 2019

September 08, 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 More

Transfer Pricing Brief: August 2019

August 05, 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

See More