| Argentina | Documentation-Deadlines: On 29 February 2020, Government published General Resolution 4680/2020 of 28 February 2020 extending again the deadline for the submission of transfer pricing returns between 20 and 24 April 2020 for fiscal periods ending between 31 December 2018 and 30 June 2019. Previously, the deadline was between 16 and 20 March, 2020. See the story in Regfollower |
| Iceland | Penalty for documentation failure: On 18 February 2020, the Ministry of Finance and Economy submitted a draft bill regarding new penalties ranges from ISK 3 to ISK 6 million for failing to comply with transfer pricing documentation requirements. See the story in Regfollower |
| Latvia | Dispute resolution-Elements of minimum standards: On 28 February 2020, OECD has published the update list of signatories and parties to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, MLI entered into force for Latvia on 1 February 2020. See the story in Regfollower Special rules for hybrid instruments or entities: On 11 February 2020, Latvia published the Law of 30 January 2020 on Amendments to the Corporate Income Tax Act in the official gazette. The law includes the provision for the implementation of the hybrid mismatch measures of the EU Anti-Tax Avoidance Directive as amended (ATAD2). See the story in Regfollower |
| Spain | Intra-group services-General: On 18 February 2020, the Spanish Cabinet reportedly approved a draft bill for the introduction of a digital services tax (DST). A 3% DST will be applicable for large companies whose respective groups have revenue of at least EUR 750 million worldwide and EUR 3 million in revenue from digital service activities in Spain. See the story in Regfollower |
| Nigeria | Comparable uncontrolled price method (“CUP”): On 19 February 2020, the Tax Appeal Tribunal made a decision regarding a transfer pricing case, entitled “Prime Plastichem Nigeria Limited v Federal Inland Revenue Service (FIRS)”, in favour of the FIRS on all the issues raised for determination and consequently, dismissed the Comparable Uncontrolled Price (CUP) method used by the Company in its 2013 financial year. See the story in Regfollower |
| Turkey | Master file-Information: On 25 February 2020, the Turkish Revenue Administration has published Presidential Decree No. 2151 in the official gazette, which amends transfer pricing documentation rules in line with OECD BEPS action 13. Accordingly, multinational enterprises (MNEs) with asset value and annual turnover at least TRY 500 million are required to prepare the master file for the accounting period after 1 January 2019. CbC reporting requirement-Timing: The first Country by Country Report must be submitted to the Turkish Tax Authority by 31 December 2020 for the fiscal year 2019. CbC notification should be submitted by end of the 6 months after the effective date of the decree. So the first CbC shall be notified to the Tax Authority until 31 August 31, 2020. APAs-Validity: The Decree increases the time limit for the effectiveness of the APA from 3 years to 5 years. Moreover, the renewal of an existing APA is reduced to 6 months from 9 months. See the story in Regfollower |
| Qatar | APAs-Bilateral: On 11 February 2020, Qatar’s General Tax Authority (GTA) has published six directives on the application of the mutual agreement procedure (MAP) including a program for entering into bilateral advance pricing agreements (APA). See the story in Regfollower |
| Australia | CbC reporting requirement-General rule: The Australian Taxation Office (ATO) has issued an email notification regarding an essential update on Country-by-Country reporting (CbCR) lodgments. ATO seeks to ensure that CbCR lodgments accepted by systems comply with the relevant requirements including identity matching of entities against details on systems; such as name, ABN and TFN. See the story in Regfollower |
| Ukraine | Requirements-Control: On 16 January 2020, the Ukrainian Parliament approved a draft law that increases in the ownership threshold from 20% to 25% for the determination of related parties. BEPS related compliance: The draft law introduced three-tiered TP documentation to multinational enterprises (MNE) resident in Ukraine consisting of master file (MF), local file (LF) and country-by-country (CbC) report in accordance with BEPS action 13. Proposed revenue thresholds are EUR 50 million for master files and EUR 750 million for CbC reports in line with OECD. See the story in Regfollower |
| Romania | Requirements-Rule: On 28 January 2020, the Government of Romania has published Ordinance no. 5 of 28 January 2020 in the Official Gazette for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements. See the story in Regfollower |
| Panama | CbC reporting requirement-General rule: On 31 January 2020, Directorate General of Revenue of Panama has issued Resolution No. 201-1035 in the official gazette, which extends the deadline for filing the Country by Country Report (CbC) and the Notification until 15 February 2020 for the fiscal year 2018. See the story in Regfollower |
| India | Safe Harbour Rule-APA: On 1st February 2020, Indian Finance Minister Nirmala Sitharaman presented the Union Budget 2020-21 in the Lok Sabha. The budget proposed that with effect from financial year (FY) 2020-21, the two dispute avoidance mechanisms namely Safe Harbour Rule (SHR) and Advance Pricing Agreements (APA) would be amended to include determination of income attributable to a PE in India. See the story in Regfollower |
Transfer Pricing Brief: March 2020
March 08, 2020
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