| Denmark | Documentation-Timing and deadlines: On 31 January 2022, the Danish Ministry of Finance issued updated guidance regarding amendments to the transfer pricing rules requiring the submission of the transfer pricing documentation within 60 days of the due date for filing the tax return, unless an extension is granted. See the story in Regfollower |
| France | CbC reporting requirement-General rule: On 14 February 2022, Government published Decree of 14 February 2022, which amends the Order 6 July 2017 pursuant to II of Article 223 quinquies C of the General Tax Code. The new Decree updates the exemption from local filing provided in the French Country-by-Country (CbC) reporting rules and includes list of jurisdictions that have adopted CbC reporting requirements. See the story in Regfollower |
| Italy | Special rules for hybrid instruments or entities: On 26 January 2022, the Italian Revenue Agency (IRA) has declared the finalization of Circular No. 2/2022. The circular clarifies the hybrid mismatch rules that has introduced as part of the Decree No. 142 of 2018, which transposed the measures of the EU Anti-Tax Avoidance Directive (ATAD). See the story in Regfollower |
| Jordan | CbC reporting requirement-General rule: On 2 February 2022, the Jordan Income and Sales Tax Department (ISTD) has issued a press release clarifying the issuance of a guide related to the preparation and submission of Country-by-Country (CbC) reports. See the story in Regfollower |
| Lithuania | Scope of transfer pricing rules: On 17 January 2022, the State Tax Inspectorate issued Order No. VA-7 of 14 January 2022, amending the rules for annual reporting on the use of reportable cross-border arrangements for DAC6. See the story in Regfollower |
| Malaysia | Restriction on interest deduction: On 31 January 2022, IRBM published the Income Tax (Restriction on Deductibility of Interest) (Amendment) Rules 2022, amending the definition of “qualifying deduction”, that goes into the formula used to determine tax EBITDA. See the story in Regfollower |
| Malta | Filing deadlines: On 27 January 2022, Malta’s Commissioner for Revenue (CFR) has notified that the deadlines for the electronic filing of corporate income tax (CIT) have been extended depending on financial year end. See the story in Regfollower |
| Romania | Filing deadlines: On 28 January 2022, the National Agency for Fiscal Administration (ANAF) of Romania has published a Notification No. 137 declaring the annual corporate income tax return and payment deadline is extended to 25 June 2022 for the tax year 2021. See the story in Regfollower |
| Slovenia | Documentation-Requirement: On 31 January 2022, the Slovenian Ministry of Finance updated the transfer pricing (TP) guidelines. The revised guidance includes the new documentation requirements and procedures for determining income and transfer pricing, including for intangible assets and services. See the story in Regfollower |
| Thailand | CbC reporting requirement-General rule: On 12 January 2022, the Thai Revenue Department has issued Notification No. 419 providing new CbC reporting requirements. Accordingly, for CbC reporting, the “reporting entity” must register for e-filing via one of two e-filing systems. See the story in Regfollower |
| Turkey | Information exchange-Bilateral: On 14 February 2022, the Turkish Revenue Administration has issued Presidential Decision No. 5191 in the Official Gazette, through which Turkey ratifies the competent authority arrangement (CAA) on the exchange of country-by-country (CbC) with US. See the story in Regfollower |
| Vietnam | Compliance with BEPS standards: On 9 February 2022, Vietnam signed the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent BEPS (the MLI). Through this MLI, Vietnam includes 75 of the 76 of its effective double tax treaties (“DTAs”) within the scope of the MLI. See the story in Regfollower |
Transfer Pricing Brief: March 2022
03 March, 2022
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