Transfer Pricing Brief: March 2021

Azerbaijan	CbC reporting requirement-General rule: Recently, Azerbaijan has introduced CbC reporting requirements and notification requirements for multinational entity groups (MNE groups) headquartered or operating in Azerbaijan. The CbC reporting requirements are applicable to MNEs Groups with a consolidated revenue of not less than EUR 750 million during the year immediately preceding the Reporting Fiscal Year. See the story in Regfollower
Croatia	Compliance with BEPS standards: On 18 February 2021, the OECD announced that Croatia has deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI will enter into force for Croatia on 1 June 2021. See the story in Regfollower Financial transactions-General: The Croatian Government has changed the arm’s length interest rate from 3.42% per annum to 3% per annum regarding loans between related parties for the year 2021. See the story in Regfollower
Cyprus	Scope of transfer pricing rules: On 3 February 2021, the Cyprus Tax Department has issued a notice regarding the extension to submission of DAC6 to 31 March 2021. See the story in Regfollower
Dominican Republic	Documentation-Requirement: On 4 February 2021, the Directorate General of Internal Revenue (DGII) published Resolution No. DDG- AR1-2021-00002, which provides new transfer pricing thresholds. According to the Resolution, the transfer pricing documentation threshold for 2021 is increased from DOP 11,552,402 to DOP 12,193,982. See the story in Regfollower
Greece	Restriction on interest deduction: On 11 January 2021, the Greek Public Revenue Authority (AADE) published Circular Ε. 2004 of 11 January 2021, which contains a 30% of EBITDA restriction with a standard safe harbor threshold of EUR 3 million in line with the EU Anti-Tax Avoidance Directive (ATAD) as amended from 1 January 2019. See the story in Regfollower Compliance with BEPS standards: On 26 January 2021, the Government Officially published Law No. 4768 to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). See the story in Regfollower
Hungary	Compliance with BEPS standards: On 22 February 2021, the Hungarian Parliament approved the bill for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). See the story in Regfollower Scope of transfer pricing rules: On 28 January 2021, the Hungarian Ministry of Finance published guidance on DAC6 reporting, which expands upon earlier guidance first issued in July 2020. See the story in Regfollower
India	Audits-Time limit and Statute of limitation: On 1 February 2021, the Finance Minister presented the Union Budget 2021-22 which proposed to reduce the length of time for assessment procedures from 24 months to 21 months (measured from the end of the assessment year). See the story in Regfollower
Ireland	Scope of transfer pricing rules: On 27 January 2021, the Irish Revenue published an eBrief No. 014/21 regarding EU mandatory disclosure of reportable cross-border arrangements. A Form DAC 6 (LPP) should be filed using MyEnquiries, setting out the identity of the relevant taxpayer and other intermediaries involved in the reportable cross-border arrangement. See the story in Regfollower
Malaysia	Digital economy transactions-General: On 1 February 2021, the Royal Malaysian Customs Department published an updated Guide on Digital Services by Foreign Service Provider (FSP), which replaces the prior guide dated 1 August 2020. See the story in Regfollower Timing and deadlines: On 2 February 2021, the Inland Revenue Board of Malaysia (IRBM) updated its transfer pricing guidelines providing the reduction of TP documentation submission deadline from 30 days to 14 days made available upon request. See the story in Regfollower
Mexico	Scope of transfer pricing rules: On 2 February 2021, Mexico has published Agreement 13/2021 in the Official Gazette which sets an aggregate tax benefit of at least MXN 100 million threshold for reportable cross-border arrangements under the Mandatory Disclosure Regime (MDR). See the story in Regfollower
Poland	Digital economy transactions-General: On 2 February 2021, the Polish Government issued a draft introducing a new advertising tax (premium) on digital (internet) advertising and conventional advertising. The online advertising premium rate will be 5%. See the story in Regfollower
Qatar	Transfer pricing information return: The General Tax Authority (GTA) of Qatar has confirmed that taxpayers filing their income tax returns via the tax authority’s Dhareeba tax portal must also file a transfer pricing (TP) declaration of related-party transactions along with their income tax returns. See the story in Regfollower
South Africa	CbC reporting requirement-Deadlines: On 19 February 2021, the South African Revenue service (SARS) Officially published Public Notice No. 101, which stated that the due date for submitting CbC report is extended to 30 June 2021 for persons who require to submit the CbC report by 31 December 2020 or 31 January 2021. See the story in Regfollower
Switzerland	Financial transactions-Restriction on interest deduction: The Federal Tax Administration of Switzerland has published two separate circulars regarding safe harbor interest rate limits applicable to shareholder and related party loans in 2021. See the story in Regfollower
Thailand	Transfer pricing information return: On 14 January 2021, the Revenue Department of Thailand has published a notice making it mandatory for companies to submit their transfer pricing (TP) disclosure forms electronically effective for accounting periods commencing on or after 1 January 2020. See the story in Regfollower
Turkey	CbC reporting requirement-Deadlines: On 22 February 2021, the Turkish Revenue Administration has issued Circular TF-3/2021-1 by which Turkey extends Country-by-Country (CbC) report filing deadline to 31 March 2021 for the ultimate parent company is resident in Turkey. See the story in Regfollower
Ukraine	CbC reporting requirement-General Rule: On 19 February 2021, the Ukrainian Ministry of Finance (MOF) has issued a press release clarifying the procedure for submitting Country-by-Country (CbC) report. See the story in Regfollower