| Argentina | Transfer pricing information return: On 31 March 2020, the Government officially published General Resolution 4689/2020 of 30 March 2020, which provides a further extension of deadline for the transfer pricing return forms between 18 May 2020 and 22 May 2020 for the financial years closed between December 31, 2018 and September 30, 2019 in response to COVID-19 pandemic. See the story in Regfollower |
| Bolivia | Standard compliance Calendar-Filing deadlines: On 28 March 2020, the Revenue Authority issued an Administrative Resolution N° 1020000000061 which extended the deadline for the submission of corporate income tax return for the year ending 31 December 2019 to 29 May 2020. See the story in Regfollower |
| Brazil | Standard compliance Calendar-Filing deadlines: On 3 April 2020, the Government published Resolution No. 154 of 3 April 2020 in the Official Gazette which postpone the deadline for filing tax return to 30 June 2020 related to tax year 2019 under the Simples Nacional regime. See the story in Regfollower |
| Canada | Requirements-Scope of transfer pricing rules: The Canada Revenue Agency (“CRA”) recently canceled Information Circular 87-2R (“IC”), which was a primary policy document on how the CRA applied transfer pricing legislation. CRA stated that IC was inconsistent with its current interpretation of Canadian transfer pricing legislation and did not reflect the updates to the OECD’s latest guidelines. See the story in Regfollower |
| Denmark | Documentation-Timing and deadlines: Denmark extends all filing deadlines, including transfer pricing documentation for the 2019 income year until 1 September 2020. See the story in Regfollower |
| France | Requirements-Scope of transfer pricing rules: On 29 April 2020, the French Tax Authority (FTA) published additional guidelines concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). See the story in Regfollower |
| Hong Kong | Digital economy transactions-General: On 27 March 2020, the Hong Kong Inland Revenue Department (IRD) released a revised version of Departmental Interpretation and Practice Notes No. 39 (Profits Tax Digital Economy, Electronic Commerce and Digital Assets-revised DIPN 39). The revised Practice Note sets out the taxation principles that broadly apply to e-commerce transactions and digital assets. See the story in Regfollower |
| India | APAs-General rule: The Finance Act 2020 passed on 27 March 2020 provides that, in the case of an APA, the income attributable to a PE can be determined based on the methods prescribed in the TP rules or in accordance with the methods provided by rules made under the Act, with such variations or adjustments as required. The new amendment has entered into force on 1 April 2020. Safe Harbour-Rule: The Finance Act 2020 enacted on 27 March 2020 extends the applicability of the safe harbor. The Indian Tax Administration (ITA) has clarified that a taxpayer can submit an APA in relation to profit attribution to a PE, if the taxpayer formally conceded the existence of a PE. The new changes will be applicable from financial year 2019-20 onwards. See the story in Regfollower Digital Economy transactions-General: On 27 March 2020, the Central Board of Direct Taxes (CBDT) published the Finance Act 2020 which received the assent of the President on the same date that includes a new equalisation levy with effect from 1 April 2020. The levy will be charged at a rate of 2% on the amount of consideration received or receivable by a non-resident “e-commerce operator” for “e-commerce supply or services” made or provided or facilitated by it. See the story in Regfollower |
| Indonesia | APAs-Validity: On 18 March 2020, the Indonesian Ministry of Finance released 22/PMK.03/2020 which updates the Advance Pricing Agreements (“APA”) regulations including simplify the APA process, the extension of validity. See the story in Regfollower Main corporate income tax rate: On 31 March 2020, Indonesia President signed the Government Regulation No. 1 for 2020 (PERPPU-1) in handling COVID-19 outbreak. Accordingly, CIT rate is reduced from 25% to 22% for tax years 2020 and 2021 and to 20% for tax year 2022 onwards. Digital economy transactions-General: A digital permanent establishment concept and an electronic transaction tax have been introduced in Regulation No. 1 for 2020 (PERPPU-1). Under this overseas sellers and e-commerce platform providers are required to appoint a representative in Indonesia to be responsible for paying and reporting the taxes related to these transactions. See the story in Regfollower |
| Kenya | Main corporate income tax rate: On 25 March 2020, the Kenyan President announced tax relief measures regarding the coronavirus (COVID-19) pandemic. The measures include a reduction in corporate tax for companies from 30% to 25%. It is expected that this rate will be effective 1st April 2020 and applicable to any financial year ending after 1 April 2020. See the story in Regfollower |
| Malaysia | CbC reporting requirement-Deadlines: Malaysia extends again deadlines for filing CbC report and notification. Previously, CbC reports and CbC notifications were extended to 15 May 2020. Now the deadline for filing CbC reports originally due 30 April 2020 is extended to 31 May 2020. The deadline for CbC notification is extended to 31 May 2020 for those CbC notifications originally due 31 March 2020 or 30 April 2020. See the story in Regfollower |
| Nigeria | Transfer pricing information return: The Federal Inland Revenue Service (FIRS) recently announced the official launch of E-TP PLAT 2.0, an electronic filing portal, for transfer pricing returns. Companies can use the e-filing platform to submit their TP declaration forms, TP disclosure forms, CbCR notification forms and CbCR reports online. See the story in Regfollower |
| Poland | Local file-deadlines: Under the provisions of the “anti-crisis shield” measures signed on 17 April 2020, the deadline for submitting the TPR-C declaration for 2019 (generally due before 30 September 2020) has been extended to 30 September 2020. See the story in Regfollower |
| Portugal | Documentation-Timing and deadlines: Portuguese government extends the deadline for preparing and submitting the transfer pricing documentation to 31 August 2020. See the story in Regfollower |
| Slovenia | Requirements-Scope of transfer pricing rules: On 2 April 2020, the Slovenian Financial Administration published new guidance on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). The guidelines describe the scope of the reporting obligations, including the hallmarks of reportable arrangements and the person required to report. See the story in Regfollower |
| Taiwan | Standard compliance Calendar-Filing deadlines: On 13 April 2020, Taiwan’s Ministry of Finance (MOF) has extended tax filing deadline to 30 June 2020 for corporate income tax originally due from 1 May 2020 to 1 June 2020. See the story in Regfollower |
| US | Documentation-Requirement: On 14 April 2020, the United States (US) Internal Revenue Service (IRS) has posted on its website new frequently asked questions (FAQs) outlining best practices and common error in preparing transfer pricing documentation. See the story in Regfollower |
Transfer Pricing Brief: May 2020
May 07, 2020
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