AustraliaSpecial rules for hybrid instruments or entities: On 16 December 2021, the Australian Taxation Office (ATO) issued Practical Compliance Guideline 2021/5 on imported hybrid mismatch rule relating to a practical administrative approach to the imported hybrid mismatch provisions in subdivision 832-H of the Income Tax Assessment Act 1997.
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CyprusCbC reporting requirement-Deadlines: On 20 December 2021, the Cyprus Tax Department published an announcement informing that the deadline for submission for local CbCR reporting due to the secondary filing mechanism (including Equivalent reporting) for the year 2020 is the 31st of January 2022 instead of the 31st of December 2021.
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FinlandOECD Guidelines: On 17 December 2021, the Finnish Tax Administration issued Guidance No. VH/5755/00.01.00/2021, on the application of OECD transfer pricing guidelines to domestic transfer pricing rules, effective from 31 December 2022.
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Adjustments: On 9 December 2021, the Finnish Parliament has approved the amendment to the transfer pricing adjustment provision, (VML Section 31) of the Tax Procedure Act (VML). The amendment will take effect on 1 January 2022 and will apply to tax years beginning on or after 1 January 2022.
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FranceSpecial rules for hybrid instruments or entities: On 15 December 2021, the Tax Authority published a guide, which covers the measures implemented in compliance with the EU Anti-Tax Avoidance Directive as amended (ATAD1 and ATAD2) as part of the Finance Law for 2020. The hybrid mismatch measures generally applies from 1 January 2020, but the anti-hybrid mismatch rules will apply from 1 January 2022.
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IcelandCbC reporting requirement-Deadlines: On 22 December 2021, Iceland published the Notice No.1490/2021 which provides that the CbC report notification in respect of the 2021 fiscal year is to be submitted by 31 January 2022.
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IndiaSafe harbor-Simplified arm’s length range: On 29 October 2021, the Central Board of Direct Taxes (CBDT) has published Notification No. 124/2021, which provides for a tolerance limit of 1% for wholesalers and 3% in all other cases for the arm’s-length pricing determination in the assessment year 2021 -22.
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IrelandCbC reporting requirement-General rule: On 20 December 2021, the Department of Enterprise, Trade and Employment is seeking the views of stakeholders through a Consultation on the transposition of the new EU directive requiring public country-by-country (CbC) reporting of income tax information by certain large multinationals. The deadline for submissions of public consultation is 18 February 2022.
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ItalyDocumentation-Requirement: On 26 November 2021, the Italian Tax Authorities issued Circular No. 15 providing clarifications on the regulations introduced on 23 November 2020 regarding the content and validity of the elective transfer pricing (TP) documentation available to Italian resident enterprises and Italian permanent establishments (PEs) of foreign entities to provide administrative penalty protection in the case of a TP assessment.
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MaltaScope of transfer pricing rules: On 22 December 2021, Malta’s Commissioner for Revenue (CFR) has published draft Transfer Pricing Rules on its website for public consultation. The consultation period will end on 28 February 2022, and the draft Transfer Pricing Rules shall come into force with effect for financial years commencing on or after 1 January 2024.
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PanamaPenalties for documentation failure: On 11 November 2021, Panama published Law No. 254 in the Official Gazette No. 29413-A, which amends the legislation on international tax transparency and the prevention of money laundering, and the financing of terrorism. The amendment includes a penalty of PAB 100,000 plus PAB 5,000 per day of non-compliance for failing to comply CbC reporting requirements.
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PolandSafe harbor-Simplified interest rates: On 24 December 2021, the Polish Official Gazette published a Regulation No. 1192, establishing base interest rates and margin rates for the purposes of transfer pricing for individual and corporate income taxes. The “Safe Harbor” interest rate applies when loans are concluded between related parties.
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PortugalDocumentation requirements: On 26 November 2021, the Portuguese Tax Administration (PTA) published Order No. 268/2021, which replaces Regulation No. 1446-C / 2001 of December 21, 2001. The ordinance changes the transfer pricing documentation rules by adding two new distinct documentation models the standard (composed of a master file and a local file) and the simplified (for small or medium-sized enterprises).
Documentation threshold: According to new order, taxpayers are exempt from the documentation requirements if, in the period to which the obligation relates, total annual income is less than EUR 10 million. Even if this limit is exceeded, that exemption shall apply to controlled transactions whose value in the period has not exceeded €100,000 and, in total, €500,000, considering their market value.
Documentation deadline: The taxpayers required to prepare the standard or the simplified model within the deadline for filing the Annual Accounting and Tax Information return (IES/DA) by the 15th day of the seventh month after the end of the financial year or on 15 July, if that Fiscal year coincides with the calendar year and can only be presented to the PTA upon request.
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South AfricaAPAs-General rules: On 10 December 2021, the South African Revenue Service (SARS) made an announcement for inviting public comments for a model and draft legislation regarding Advance Pricing Agreement (APA) system until the end of January 2022.
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SpainMAP: On 19 November 2021, the tax authorities have issued a guide and questions and answers (Q&As) on mutual agreement procedures (MAPs) to provide taxpayers with guidance on the main aspects of MAP.
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ThailandCbC reporting requirement-Deadlines: On 23 December 2021, the Thai Revenue Department has published a notification on amendments to the filing deadlines for Country-by-Country (CbC) reports. Accordingly, the CbC reporting deadline has been amended to 12 months after the close of the relevant accounting period.
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US and TurkeyInformation exchange-Bilateral: On 24 November 2021, US and Turkey have signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. A CbC report is intended to be first exchanged with respect to Fiscal Years of MNE Groups commencing on or after 1 January 2019.
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ZambiaCbC reporting requirement-General rule: On 29 October 2021, the Zambian government has presented the budget for 2022 to the Parliament. The budget introduces two new schedules that allow taxpayers to provide the information required by international country-by-country reporting (CbC) obligations, and it adds tax measures to encourage investment in special economic zones and the mining sector.
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