AustraliaCbC reporting requirement-Deadlines: On 18 November 2021, the Australian Taxation Office (ATO) announced that country-by-country (CbC) reporting entities that have a CbC reporting obligation due by 31 December 2021 will now have until 4 February 2022 to file (lodge) such CbC reporting statements due to the year-end holidays and the ongoing impacts of Covid-19.
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Restriction on interest deduction: On 11 November 2021, the Australian Taxation Office (ATO) amended its practical compliance guideline on simplified transfer pricing record-keeping options to provide maximum and minimum interest rates for low-level inbound and outbound loans for 2022.
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AzerbaijanScope of transfer pricing rules: On 16 November 2021, Azerbaijan has revised the tax code including scope of controlled transactions and increasing the penalty for failing CbC reports on transfer pricing.
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CyprusScope of transfer pricing rules: On 22 November 2021, the Cyprus Tax Department has published an announcement extending administrative fines for overdue submission of DAC6 reporting until 31th January 2022.
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Scope of transfer pricing rules: On 29 October 2021, the tax department of Cyprus published the Decree KDP 438/2021 for the implementation of the EU directives on reportable cross-border arrangements (DAC6).
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DenmarkDocumentation-Requirement: On 25 November 2021, the Danish Parliament passed Draft Law No. L7, which largely abolishes the obligation to include domestically, controlled transactions in the Transfer Pricing Documentation (TP). The exemption of purely Danish transactions applies to financial years beginning on or after 1 January 2021.
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EstoniaCompliance with BEPS standards: On 25 November 2021, the Organization for Economic Cooperation and Development (OECD) has announced that Estonia deposited new notifications under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) subsequent to their ratification. The MLI entered into force for Estonia on 1 May 2021.
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FinlandSpecial rules for hybrid instruments or entities: On 29 October 2021, the Parliament of Finland has adopted the Bill No.204/2021 to amend cross-border hybrid mismatch rules, implementing the EU anti-avoidance directives. The bill includes measures to transpose the reverse hybrid mismatch rules as per Article 9(a) of the EU Anti-Tax Avoidance Directive as amended (ATAD2).
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KenyaCbC reporting requirement-General rule: On 19 November 2021, Kenya Revenue Authority has opened a consultation regarding drafted country-by-country (CbC) reporting regulation. The submissions should be addressed to the Commissioner General of Kenya Revenue Authority, to be received on or before Friday, 10th December, 2021.
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MaltaScope of transfer pricing rules: On 17 November 2021, the Commissioner for Revenue (CFR) notifies that version 1.1 of the updated Guidelines on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements (DAC 6) is available for download.
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MexicoTransfer pricing information return: On 26 October 2021, Mexican Congress has approved the economic package for the year 2022. Accordingly, information return reporting regarding transactions with related parties would be due no later than 15 May instead of 31 December of the immediately succeeding year, and this would apply to both transactions with foreign and domestic related parties.
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RomaniaDocumentation-Requirement: On 29 October 2021, the Romanian National Tax Agency (NTA) published Order No. 1721 that revises the list of large taxpayers those are subject to prepare transfer pricing (TP) documentation. There are currently 2,940 large taxpayers until 31 December 2021 and starting from 1 January 2022, the updated list now includes 3,364 taxpayers.
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RussiaFinancial transactions-General: On 18 November 2021, the Russian Ministry of Finance (MoF) published a Guidance Letter No. 03-03-07 / 85525 clarifying that a loan is considered a controlled debt for Transfer Pricing (TP) purposes if it is granted to a Russian company by a third party subject to meet certain conditions.
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TaiwanCbC reporting requirement-Deadlines: On 9 November 2021, Taiwan’s National Tax Bureau of the Southern Area has indicated that constituent entities of multinational enterprise groups shall submit Master File or Country-by-Country Report within one year after the end of the fiscal year. The filing of 2020 income tax return was due at the end of June this year (2021).
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UkraineAPAs-General rules: On 28 October 2021, the Cabinet of Ministers of Ukraine has adopted new procedures of preliminary coordination of advance pricing agreements (APAs) in controlled transactions through Decree No. 504. The Decree replaces previous Decree No. 504 of 17 July 2015 which provided the procedure for obtaining APAs. The New Procedure will become effective from 1 January 2022.
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US and IndiaDigital economy transactions-General: On 24 November 2021, the United States and India concluded an agreement on a transitional approach to the treatment of the current Indian E-commerce Equalization Levy (EL) in the transition period prior to the full implementation of Pillar 1 addressed by OECD.
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US and TurkeyDigital economy transactions-General: On 22 November 2021, the U.S. treasury department announced that the United States and Turkey have reached a political agreement with Turkey on the treatment of taxes on digital services (DST) in the transition period prior to the full implementation of Pillar 1 of the Organization for Economic Co-operation and Development (OECD) agreement.
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