| Colombia | Documentation/CbC reporting/Master file/Local file: On 20 December 2021, the Colombian Ministry of Finance and Public Credit has issued Decree 1778 specifying the deadlines for transfer pricing (TP) documentation, including local/master file and CbC reports. The deadline for informative transfer pricing returns and Local files is 7 September to 20 September 2022. The deadline for CbC reports is between 12 December to 26 December 2022, and the Master file is between 12 December to 23 December 2022. See the story in Regfollower |
| Croatia | Financial transactions-General: The Ministry of Finance announced a new interest rate of 2.68% on loans between related parties for 2022. Accordingly, the interest is calculated at the rate of 2.68% of the minimum required tax revenue for 2022 when a domestic company gives a loan to a foreign affiliate. See the story in Regfollower |
| Cyprus | Financial transactions-General: On 24 January 2022, the Cyprus Tax Department published a new “Frequently Asked Questions (FAQs)” section on its website on Transfer Pricing (TP). The FAQs relate to the Interpretative Circular 3 issued on 30 June 2017 (Back-to-Back Circular). The Back to Back Circular applies to both cross-border transactions and domestic transactions between related companies. See the story in Regfollower |
| Czech Republic | Information exchange-Multilateral: On 20 January 2022, the Finance Ministry published Finance Bulletin No.3/2022, which updates the list of jurisdictions participating in the exchange of country-by-country (CbC) reports for the 2021 reporting period. See the story in Regfollower |
| Ireland | Restriction on interest deduction: On 21 December 2021, President signed the 2021 Finance Bill into Finance Act 2021 including new interest limitation rules. These rules are intended to limit base erosion through the use of excessive interest deductions. The rules will take effect for accounting periods of companies beginning on or after 1 January 2022. See the story in Regfollower |
| Jordan | Transfer pricing information return: On 2 January 2022, the Jordan Income and Sales Tax Department (ISTD) has published new transfer pricing documentation forms (Arabic) in line with Regulation No. 40 of 7 June 2021. Taxpayers with related party transactions equal to JOD 500,000 or more in a 12-month period are required to submit a transfer pricing disclosure with the annual tax return. See the story in Regfollower |
| Nigeria | CbC reporting requirement-General rule: On 4 January 2022, the Federal Inland Revenue Service (FIRS) issued a new Public Notice to announce that the withdrawal of its Public Notice of 6 May 2021 which suspended local filing obligations contained in Regulation 4 of the Income Tax (CbC Reporting) Regulations, 2018 imposed on branches and subsidiaries of Multinational Enterprises (MNEs) operating in Nigeria. See the story in Regfollower |
| Peru | Restriction on interest deduction: On 30 December 2021, the Peruvian Tax Administration (SUNAT) has issued Supreme Decree 402-2021-EF in the Official Gazette clarifying the regulations for interest deduction limitation rules. From 1 January 2021, interest exceeding 30% of EBITDA in the previous year will not be deductible. See the story in Regfollower |
| Singapore | Information exchange-Multilateral: On 21 December 2021, Singapore published the Income Tax Order 2018 including the addition of a seventh schedule listing the jurisdictions with which the CbC report exchange is effective as of 1 December 2020, and the addition of an eighth schedule listing the jurisdictions with which the CbC report exchange is effective from 31 March 2021. See the story in Regfollower |
| Spain | Compliance with BEPS standards: According to OECD’s latest publication regarding the position of signatories’ countries on the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), MLI entered into force for Spain on 1 January 2022. See the story in Regfollower |
| Ukraine | Compliance with BEPS standards: On 29 December 2021, the Ukraine Ministry of Finance has announced that the government has approved amendments to the law ratifying the tax treaty related measures to prevent Base Erosion and Profit Shifting (MLI). BEPS MLI entered into force with respect to Ukraine on 1 December 2019. See the story in Regfollower |
Transfer Pricing Brief: February 2022
February 04, 2022
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