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 new TP documentation requirements and a framework for taxpayers to apply for Advance Pricing Agreements.
See the story in Regfollower
Germany Scope of transfer pricing rules: On 5 July 2022, the German Federal Ministry of Finance published a draft decree-law regarding the transfer of functions. The aim of the draft decree-law is to adapt and restructure the existing regulations on the arm’s length principle with the current measures under the OECD Transfer Pricing Guidelines.
See the story in Regfollower
Hungary Comparability-Range: On 19 July 2022, the Hungarian Parliament passed a bill introducing important changes to the transfer pricing rules. The law introduces a significant additional reporting requirement for intra-group transactions and requires transfer pricing adjustments to be made at the median.
See the story in Regfollower
India Comparability-Range: On 28 June 2022, the Indian CBDT issued Notification No. 70/2022, clarifying the calculation procedure of the arm’s length price under the income tax act. The notification provides a tolerance range of 1 % for wholesale trading and 3 % for all the other cases for AY 2022-23.
See the story in Regfollower
Ireland Special rules for hybrid instruments or entities: On 29 June 2022, the Irish Revenue published an e-Brief No. 137/22 introducing the reverse hybrid rule and key definitions regarding the operation of anti-hybrid rule under EU directive (ATAD-2).
See the story in Regfollower
Israel Documentation: On 30 June 2022, the Israeli Parliament passed legislation to amend Section 85A of the Income Tax Ordinance (ITO) and its regulations, by introducing three-tiered transfer pricing documentation requirements of BEPS Action 13.
See the story in Regfollower
Kenya Related party definition: On 8 July 2022, the Kenyan Finance Act 2022 was gazetted which was signed into law by the President on 21 June 2022. The Act amended Section 18(A) of the ITA to expand the scope of transactions within the scope of transfer pricing legislation in Kenya.
CbC reporting requirement-General rule: The Finance Bill 2022 introduces a new Section 18B, as well as new Sections 18C, 18D, 18E and 18F that provide more detailed CbC reporting requirements, as well as master and local file requirements.
See the story in Regfollower
Lithuania APAs-General rules: Recently, the State Tax Inspectorate of the Ministry of Finance of the Republic of Lithuania revised the Lithuanian Advance Pricing Agreements (APAs), which came into effect on 31 March 2022.
See the story in Regfollower
Nigeria Filing deadlines: On 4 July 2022, the Federal Inland Revenue Service (FIRS) of Nigeria has announced to extend the submission of company income tax return for the 2022 year of assessment. Accordingly, the filing of CITR for the 2022 YA, due on 30th June 2022, has been extended to 31st August 2022.
See the story in Regfollower
Paraguay Transfer pricing information return: On 23 June 2022, the tax authority has extended the deadlines to submit the transfer pricing (TP) informative returns related to commodities exports through General Resolution 116. The Resolution came into force on 24 June 2022.
See the story in Regfollower
Portugal Documentation-Timing and deadlines: On 6 July 2022, the government published an announcement extending the deadlines for preparation and/or submission of TP documentation from 15 July to 15 September 2022 without any accruals or penalties.
See the story in Regfollower
Saudi Arabia Scope of transfer pricing rules: On 4 July 2022, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued a draft of Transfer Pricing (TP) Bylaws and invited public consultation. The final Transfer Pricing Bylaws will be released within the next two months and applicable during the fiscal year ending 31 December 2022.
See the story in Regfollower
South Korea MAP: On 30 June 2022, South Korea’s National Tax Service (NTS) has issued updated Mutual Agreement Procedure (MAP) guidance on the official website.
See the story in Regfollower
Tanzania Digital economy transactions-General: On 28 June 2022, the National Assembly approved Finance Bill 2022 introducing Digital Service Tax at the rate of 2% on the turnover of the non-resident service providers.
See the story in Regfollower
Thailand Compliance with BEPS standards: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Thailand on 1 July 2022.
See the story in Regfollower