| Argentina | Filing deadlines: On 28 April 2022, the Federal Public Revenue Administration (AFIP) published General Resolution 5189/2022 of 28 April 2022, which extends the submission deadline of corporate tax return to between 23 and 26 May 2022. See the story in Regfollower |
| Austria | MAP: On 6 May 2022, the Ministry of Finance issued new guidelines on mutual agreement and arbitration procedures (MAP) under the Austrian double taxation agreements, the EU Arbitration Convention, the BEPS Multilateral Instrument (MLI), and the EU Tax Dispute Settlement Act. The guidance replaces the previous guidance no. BMF-010221/0237 of 24 July 2019. See the story in Regfollower |
| Bangladesh | Filing deadlines: On 16 May 2022, the National Board of Revenue (NBR) of Bangladesh has published a Notice regarding the extension of the deadline for the filing of corporate income tax (CIT) returns for the 2020-2021 income year ended on 30 June 2021. See the story in Regfollower |
| Belgium | Filing deadlines: On 9 May 2022, the Federal Public Service Finance (SPF) of Belgium has issued a Notice declaring that the corporate income tax (CIT) return submission deadline is 17 October 2022 for the fiscal years ending from 31 December 2021 to 28 February 2022. See the story in Regfollower |
| Canada | Special rules for hybrid instruments or entities: On 29 April 2022, the Finance Department published a draft legislation proposal that would address hybrid mismatch arrangements, which are used primarily by multinational enterprises to avoid paying their fair share of tax, as committed to in Budget 2021. See the story in Regfollower |
| China | Compliance with BEPS standards: On 25 May 2022, China has deposited its instrument of approval for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention). China’s instrument of approval also covers Hong Kong (China)’s bilateral tax treaties. The Convention will enter into force on 1 September 2022 for China and Hong Kong. See the story in Regfollower |
| Denmark | Timing and deadlines: Denmark recently introduced new filing requirements for transfer pricing documentation, requiring annual filing of the TPD. The deadline for filing the compliant documentation is 60 days after the due date for filing the annual corporate income tax return. Therefore, the deadline for transfer pricing documentation submission for the financial year ended 31 December 2021 is 29 August 2022. See the story in Regfollower |
| Greece | Information exchange-Multilateral: On 18 April 2022, the Greek Public Revenue Authority (AADE) published Circular A.1051 of 18 April 2022, which determines the lists of jurisdictions with which Greece wants implement the Multilateral Competent Authority Agreement on the exchange of Country-by-Country (CbC) reports. See the story in Regfollower |
| Luxembourg | Scope of transfer pricing rules: On 4 May 2022, the Luxembourg Tax Authorities has updated guidelines concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) as per Council Directive (EU) 2018/822 of 25 May 2018. See the story in Regfollower |
| Malta | Scope of transfer pricing rules: On 29 April 2022, Malta’s Commissioner for Revenue (CFR) has published “frequently asked questions” (FAQs) on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements (DAC6). See the story in Regfollower |
| Russia | Scope of transfer pricing rules: On 26 April 2022, the Ministry of Finance and Federal Tax Service (FTS) published a Guidance Letter 03-12-12/1/37761 clarifying the criteria for qualifying transactions as controlled for transfer pricing purposes. The letter states that taxpayers must report to the tax authorities all controlled transactions listed in Article 105.14 carried out in a calendar year. See the story in Regfollower |
| Singapore | Filing deadlines: On 4 May 2022, the Inland Revenue Authority of Singapore published guidance on the 2022 corporate tax filing season. The guidelines include submission procedures, applicable thresholds, and guidelines for CIT forms. The deadline for filing your Corporate Income Tax Return (Form C-S/ Form C-S (Lite)/ Form C) for the Year of Assessment 2022 is 30 November 2022. See the story in Regfollower |
| Taiwan | Filing deadlines: On 4 May 2022, Taiwan’s Ministry of Finance (MOF) has extended the deadline for filing income tax return for the tax year 2021 from 31 May 2022 to 30 June 2022 due to the COVID-19 pandemic. See the story in Regfollower |
Transfer Pricing Brief: June 2022
June 03, 2022
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