Transfer Pricing Brief: July 2019

Panama	CbC reporting requirement-General rule: On 27 May 2019, Panama introduced Country-by-Country (CbC) reporting requirements for MNE’s whose consolidated group revenue exceeds €750 million. Timing: The CbC report must be filed no later than 12 months after the last day of the reporting fiscal year of the MNE group. Penalty for non-compliance: The penalties for failing to comply with the CbC requirements (either CbC reporting or CbC notification) are USD 1,000 to USD 5,000 for the first offense and fines of USD 5,000 to USD 10,000 for repeat offenses. See the story in Regfollower
Argentina	Specific TP compliance-Form: On 27 May 2019, the Argentine tax authorities published the General Resolution No.4496 (GR 4496) that eliminates Form 969, which was due 28 May 2019 for the tax year ending 31 December 2018 since most of the information now included as part of form F.743. See the story in Regfollower Specific TP compliance: On 10 June 2019, Argentina amended transfer pricing compliance requirements for local transaction under the General Resolution No.4502. Form F 968 for transactions carried out in the domestic market with any related party will no longer applies from beginning with the July 2019 deadlines. See the story in Regfollower
Singapore	Requirements-Rule: On 24 May 2019, the Inland Revenue Service of Singapore (IRS) published a new transfer pricing (TP) E-Tax guide regarding commodity marketing and trading activities to comply with the arm’s length principle and documentation requirements. See the story in Regfollower
Australia	BEPS related compliance: The Australian Taxation Office (ATO) provided additional 15 days (until 15 July 2019) for the lodgment of CbC statements (Local File, Master File, CbC report) with 30 June 2019 due date because of technical issues. See the story in Regfollower
Bulgaria	Documentation-Threshold: On 5 June 2019, Parliament voted at first reading on changes to the Tax and Social Security Proceedings Code. The changes were made at the threshold for the preparation of compulsory transfer pricing documents for loan transactions by lowering BGN 1 million (BGN 2 million in the initial proposal) or interest payments exceeding BGN 50,000 (BGN 100,000 suggested initially). See the story in Regfollower
Spain	Tax returns must be filed: On 17 May 2019, Spain approved the corporate income tax and non-resident income tax returns corresponding to permanent establishments and entities under the regime of attribution of income established abroad with a presence in Spanish territory, for the tax periods started between January 1, 2018 and December 31, 2018. See the story in Regfollower
Czech Republic	Requirements-Rule: On 31 May 2019, Czech Ministry of Finance published new a guidance that briefly cover the transfer pricing documentation, more detailed recommendations for benchmarking, including the recommended update period. See the story in Regfollower
Colombia	Master and Local File: On 22 May 2019, the Colombian tax authority (DIAN) outlined the procedure for submitting Master file and Local file corresponding to the tax year 2018 and partial of 2019. Form 5231 V-2 will be used for the preparation of Master File and 1729 V-8 will be used for Local file. Specific TP compliance: On 22 May 2019, the Colombian tax authority (DIAN) provided guidelines for submission of TP return form corresponding to the tax year 2018 and partial of 2019. Transfer pricing return (Form 120) must be submitted using DIAN’s e-services. See the story in Regfollower
Uganda	Restriction on interest deduction: Under the income tax amendment act 2019 which were enacted on 14 June 2019, financial institution or person carrying on insurance business will not allow to deduct interest expense for related party debt. See the story in Regfollower
Russia	Treaty Application: On 18 June 2019, the Russian Federation deposited its instrument of ratification for the BEPS MLI. According to the date of deposit, the MLI for Russia will enter into force on 1 October 2019, although its entry into force for Russia’s covered agreements (tax treaties) will depend on the ratification of the MLI by the counterparty to a particular covered agreement. See the story in Regfollower Adjustments-MAP: The Ministry of Finance proposed some transfer pricing amendments including the development of a mutual agreement procedure (MAP) process under the draft legislation No.720839-7. The draft law has been submitted to the State Duma for approval, if enacted would be effective 1 January 2020. See the story in Regfollower CbC reporting requirement-General rule: On 7 June 2019, the Russian parliament passed Law No. 125-FZ in the Official Gazette. The Act amends Article 105.16.3 of the Tax Code on the submission of country-by-country (CbC) reports by multinationals (MNE). See the story in Regfollower
Slovenia	Main corporate income tax rate: On 18 June 2019, the Ministry of Finance proposed changes to corporate income tax (CIT) rate, which are expected to be introduced in 2020. See the story in Regfollower
India	Treaty Application: On 25 June 2019, India has deposited its instrument of ratification for the BEPS MLI. According to the date of deposit, the MLI for India will enter into force on 1 October 2019, but it depends on the ratification of the MLI by the counterparty to a particular covered agreement. See the story in Regfollower
Saudi Arabia	Information exchange-Multilateral: On 28 May 2019, the Saudi Arabian Cabinet authorized the Minister of Finance to sign the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA). See the story in Regfollower
Poland	Comparability: On 19 June 2019, Poland Ministry of Finance published an explanatory note addressing transfer pricing comparability analyses. Accordingly, database for comparables could be selected locally, regionally, or even globally by considering comparability factors, including proper identification of a suitable market. See the story in Regfollower
Belgium	Coordination of Domestic and Cross-Border Dispute Resolution Procedures: On 17 May 2019, Belgium published a Law which transposes EU directive on tax dispute resolution mechanisms in the European Union. The directive lays down rules on a mechanism to resolve disputes between Member States when those disputes arise due to a mismatch in national rules or different interpretations of a bilateral tax treaty with regards transfer pricing arrangements. See the story in Regfollower