| Chile | Compliance 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 (MLI). Accordingly, MLI entered into force for Chile on 1 March 2021. See the story in Regfollower |
| Costa Rica | APAs-General rules: On 24 March 2021, the Costa Rican Ministry of Finance released a Resolution No. DGT-R-14-2021, providing new guidelines on advance pricing agreements (APAs). The resolution provides the details guidelines of APAs procedures. See the story in Regfollower |
| Dominican Republic | Scope of transfer pricing rules: On 1 March 2021, the Directorate General of Internal Revenue (DGII) made an announcement of launching a public consultation on the draft modification of 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. See the story in Regfollower |
| Greece | Compliance with BEPS standards: On 30 March 2021, the OECD announced that Greece has deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI will enter into force for Greece on 1 July 2021. See the story in Regfollower |
| Hungary | Compliance with BEPS standards: On 3 March 2021, the Hungarian President ratified the law, that was approved by the Hungarian Parliament on 22 February 2021, and promulgated the MLI in Hungary. The ratification process was completed on 4 March 2021 by publishing the approved bill in the Official Gazette. See the story in Regfollower |
| Ireland | Special rules for hybrid instruments or entities: On 29 March 2021, the Irish Revenue published an eBrief No. 068/21 to announce a manual to update the guidance on anti-hybrid rules. The anti-hybrid rules apply to all corporate taxpayers; there is no de minimis threshold below which the rules do not relate, and the rules apply to all payments made after 1 January 2020. See the story in Regfollower Scope of transfer pricing rules: On 1 March 2021, the Irish Revenue published an eBrief No. 014/21 regarding EU mandatory disclosure of reportable cross-border arrangements. See the story in Regfollower Scope of transfer pricing rules: On 24 February 2021, the Irish Revenue issued eBrief No. 37/21 regarding updated guidance on transfer pricing. On the similar day, the Revenue also published a Tax and Duty Manual-Part 35A-01-01, providing updated guidance on the operation of the transfer pricing rules in Part 35A Taxes Consolidation Act 1997 as updated by Finance Act 2019. See the story in Regfollower |
| Italy | Digital economy transactions-General: On 9 March 2021, the Ministry of Economy and Finance of Italy announced the further extended deadlines for filing the digital services tax (DST) return and payment of tax for FY 2020. See the story in Regfollower |
| Luxembourg | MAP: On 11 March 2021, the Luxembourg Tax Authorities has issued Circular L.G. – Conv. D.I. n° 60 regarding the updated mutual agreement procedure (MAP). The Circular replaces previous Circular L.G. Conv. D.I. No. 60 of 28 August 2017. See the story in Regfollower |
| Peru | Application to intra-group services: On 18 March 2021, the Peruvian tax authorities (SUNAT) has issued Report No. 135-2020-SUNAT/7T0000, through which SUNAT announced the use of the most appropriate to determine the market value of services other than those classified as low value-adding in the case of intra-group services provided before 2019. See the story in Regfollower |
| Qatar | Transfer pricing information return: On 1 March 2021, the Decision No.4 of 2020 that was issued on 16 July 2020 by the GTA has been publicly released, which confirms the obligation to submit the transfer pricing (TP) disclosure form, master file, and local file applies to taxable years beginning on or after 1 January 2020 for taxpayers that exceed the revenue and asset thresholds. See the story in Regfollower |
| Serbia | Restriction on interest deduction: On 19 March 2021, the Serbian Ministry of Finance has published the Rulebook on Arm’s Length Interest Rates applicable for 2021 that applies on related parties’ loans. Rulebook comes into force on 27 March 2021. See the story in Regfollower |
| UK | CbC reporting requirement-General rule: The UK tax authority has updated the country-by-country (CbC) reporting schema to XML 2.0 for submissions to HM Revenue & Customs (HMRC). All CbC reports must use the new 2.0 XML format and submitted to HMRC on or after 1 January 2021. See the story in Regfollower Documentation-Requirement: On 23 March 2021 the UK government published a consultation paper on transfer pricing documentation. The consultation document sets out the case for strengthening the UK transfer pricing documentation requirements to align UK practice more closely with that of other comparable tax administrations and to provide better data to HMRC and more certainty to taxpayers. See the story in Regfollower |
| US | APAs-General rules: On 23 March 2021, the US IRS released an advance version of Announcement 2021-6 regarding the Advance Pricing and Mutual Agreement (APMA) program’s annual report on advance pricing agreements (APAs) for 2020. This twenty-second report describes the experience, structure, and activities of the APMA Program during calendar year 2020. See the story in Regfollower |
| Zambia | CbC reporting requirement-General rule: On 31 December 2020, Zambia has published the Income Tax (Transfer Pricing) (Amendment) Regulations under Statutory Instrument No. 117 of 2020. The Regulations introduce country-by-country (CbC) reporting requirements, which are effective from 1 January 2021. See the story in Regfollower |
Transfer Pricing Brief: April 2021
April 05, 2021
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