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 are taking up the local file administrative solution.
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Local file-General rule: On 15 July 2021, the Australian Taxation Office (ATO) has published the Local file instructions for 2021. These instructions apply to the local file for 2021.
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CyprusScope of transfer pricing rules: On 29 July 2021, the Cypriot Tax Department issued a new XML Schema regarding DAC6/MDR submissions that entered into force on 5 August 2021.
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FranceScope of transfer pricing rules: Recently, the Tax Authority has published a notice to announce that the online service for reporting on DAC6 cross-border arrangements will be suspended in the private and professional areas from July 29, 2021 until the beginning of September 2021.
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GermanyFinancial transactions-Restriction on interest deduction: On 14 July 2021, the German Ministry of Finance published a decree providing updated administrative principles on transfer pricing. The new decree contains some provisions on intra-group financing structures. Accordingly, a German borrower may only deduct a risk-free market return as an arm’s length expense.
Applicable methods-Priority of methods: The new decree states that the OECD guidelines on transfer pricing methodologies should be followed and the method most appropriate for the underlying case should be used.
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GreeceCompliance with BEPS standards: On 29 June 2021, OECD has published the updated position of signatories’ countries regarding BEPS MLI. Accordingly, MLI entered into force for Greece on 1 July 2021.
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HungaryCompliance with BEPS standards: On 1 July 2021, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Hungary. The provisions of the MLI will generally apply for a covered agreement from 1 January 2022.
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Ireland Scope of transfer pricing rules: On 20 July 2021, the Revenue published an eBrief 142/21 and a tax and duty manual, which amend filing guidelines for DAC6 at Section 7.4 to include a revised date for the re-opening of the portal of 17 August 2021.
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OmanLocal file-Deadlines: The tax authority of Oman has announced that Multinational Enterprises (MNEs) and its subsidiaries and branches operating in the Sultanate of Oman that the implementation of local filing requirements is suspended until further notice.
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PolandDocumentation-Timing and deadlines: On 28 June 2021, Poland Ministry of Finance issued a plans for taxpayer-friendly amendments to the transfer pricing regulations. The amendment includes an extension of the deadline for the submission of local transfer pricing documentation by the taxpayer to 14 days at the request of the tax authority.
Local file-Deadlines: Extension of the deadline for the preparation of local transfer pricing documentation until the end of the tenth month after the end of the entity’s tax year.
Transfer pricing information return: Cancellation on the preparation of transfer pricing documentation and the arm’s length nature of the applied transfer prices as a separate document rather to merge each other into the transfer pricing information return (TPR) so that only one form is required.
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South AfricaInformation exchange-Multilateral: The South African Revenue Service (SARS) published a latest list of jurisdictions. These listed jurisdictions have CbC report exchange agreements with South Africa from 22 June 2021.
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Sri LankaCbC reporting requirement-General rule: Sri Lanka has published amended Transfer Pricing (TP) Regulations that amended the CbC reporting threshold from group revenue of LKR 115 billion to group revenue of EUR 750 million or LKR equivalent in the previous year.
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