| Argentina | Transfer pricing information return: On 18 June 2021, the Federal Administration of Public Revenues (AFIP) officially published General Resolution 5010/2021, which extends the deadline for filing transfer pricing reports and related forms for tax years ended between 31 December 2020 and 31 December 2021. See the story in Regfollower |
| Canada | MAP: On 1 June 2021, the Canada Revenue Agency (CRA) published an Information Circular IC71-17R6 regarding Mutual Agreement Procedures which replaces and cancels the Information Circular 71-17R5 released on 1 January 2005. See the story in Regfollower |
| Croatia | Compliance with BEPS standards: According to OECD publication on 29 June 2021 regarding the BEPS (MLI), the convention entered into force for Croatia on 1 June 2021. Croatia was signed the convention on 7 June 2017 and was deposited its instrument on 18 February 2021. See the story in Regfollower |
| Cyprus | Scope of transfer pricing rules: On 3 June 2021, the Cyprus tax department has issued a notice providing an extension to the imposition of administrative fines for overdue submission of DAC6 reporting until the 30th September 2021. See the story in Regfollower |
| Jordan | Scope of transfer pricing rules: On 7 June 2021, the Hashemite Kingdom of Jordan has published Regulation No. 40 of 2021 introducing transfer pricing rules for multinational entity (MNE) groups with effect from 7 July 2021. See the story in Regfollower |
| Luxembourg | Restriction on interest deduction: On 2 June 2021, the Luxembourg Tax Authorities has published Circular L.I.R. n° 168bis, which clarifies certain aspects of the interest expense deduction limitation. The tax deduction for interest and other borrowing costs is limited to 30% of earnings before interest, taxes, depreciation, and amortization (EBITDA) or EUR 3 million. See the story in Regfollower |
| Malaysia | Compliance with BEPS standards: According to OECD publication on 29 June 2021 regarding the BEPS (MLI), the convention entered into force for Malaysia on 1 June 2021. See the story in Regfollower CbC reporting requirement-Deadline: On 25 May 2021, the Inland Revenue Board of Malaysia announced on its website that starting from the year of assessment (YA) 2021, constituent entities can now furnish the Country-by-Country Reporting (CbCR) Notification using the C Form. See the story in Regfollower |
| Morocco | MAP: The Ministry of Finance (MoF) of Morocco has published guidance on the mutual agreement procedure (MAP), which provides a dispute resolution procedure to resolve tax treaty related disputes. See the story in Regfollower |
| Portugal | Documentation-Timing and deadlines: According to the Order No. 191/2021-XXII of 15 June 2021, Portugal has extended the deadline for the preparation of transfer pricing (TP) documentation (and submission if required) to 22 July 2021 (usually by 15 July). See the story in Regfollower |
| Qatar | Master File-Local File-Deadlines: On 17 June 2021, the General Tax Authority (GTA) of Qatar published Decision No. 8 of 2021 extending the deadline for submission of the Master file and Local file from 30 June 2021 to 30 September 2021 for the 2020 fiscal year. See the story in Regfollower |
| Singapore | Adjustments-Primary adjustment: On 1 June 2021, the Inland Revenue Authority of Singapore (IRAS) has published second edition of e-Tax Guide GST-Transfer Pricing Adjustments. The e-Tax guide explains the GST treatment for adjustments on the transfer prices of transactions between related parties. See the story in Regfollower |
| Spain | Digital economy transactions-General: On 11 June 2021, Spain published the form 490 for the digital services tax that was approved on 9 June 2021. The new form will only be available in electronic form and must be submitted electronically. See the story in Regfollower MAP: On 8 June 2021, the Spanish government has published a Royal Decree 399/2021 which amends the Regulation on Mutual Agreement Procedures (MAP) as approved by Royal Decree 1794/2008. See the story in Regfollower |
| UAE | MAP: The Ministry of Finance (MoF) of the United Arab Emirates (UAE) has published guidance on the mutual agreement procedure (MAP), which provides a dispute resolution procedure to resolve tax treaty related disputes. See the story in Regfollower |
| Vietnam | APAs-General rules: On 18 June 2021, the Vietnamese Ministry of Finance (MoF) has issued Circular 45/2021/TT-BTC, which sets out new rules on Advance Pricing Agreements in Vietnam. The Circular takes effect from 3 August 2021, replacing Circular No. 201/2013/TT-BTC dated 20 December 2013 of the Ministry of Finance. See the story in Regfollower |
Transfer Pricing Brief: July 2021
July 06, 2021
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