| Algeria | Filing deadlines: The Directorate General of Taxes has recently issued a communiqué, which provides extension of filing deadline of annual tax returns (including balance sheet and appendices) 2020 until 30 June 2021 for all companies. See the story in Regfollower |
| Canada | Digital economy transactions-General: On 19 April 2021, the Finance Minister presented Budget 2021 including a proposal 3% digital service tax, which would apply only to large businesses with gross revenue of at least 750 million euros. The rate would apply on revenue from digital services that rely on data and content contributions from Canadian users. See the story in Regfollower |
| Cyprus | Scope of transfer pricing rules: On 31 March 2021, the Cyprus official gazette published the law (Ν. 41(Ι)/2021, the Law) amending the Law on Administrative Cooperation in the field of Taxation (Law N. 205(I)/2012). The Law transposed the EU Council Directive 2011/16 referred to as DAC6 into domestic law. See the story in Regfollower |
| Finland | Filing deadlines: On 9 April 2021, Finnish Tax Administration has published an announcement providing one-month extension of filing deadline for corporate income tax returns. The tax return can now be filed within five months from the end of the accounting period. Normally, the tax return must be filed within four months. See the story in Regfollower |
| Germany | Scope of transfer pricing rules: On 29 March 2021, the German Ministry of Finance has published the final decree regarding the application of the mandatory disclosure rules relating to certain cross-border tax arrangements as per Council Directive (EU) 2018/822 of 25 May 2018. See the story in Regfollower Compliance with BEPS standards: On 16 March 2021, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, MLI entered into force for Germany on 1 April 2021. See the story in Regfollower |
| India | Master File-General Rule: On 5 April 2021, the Indian Central Board of Direct Taxes (CBDT) has released a Notification No. 31/2021 which include the changes of Master File requirement. Accordingly, where there is more than one constituent entity of an international group that would be required to file the Master file, only one entity is required to file if it has been designated for this purpose and this has been conveyed to the authority. CbC reporting requirement- Threshold: On 5 April 2021, the Indian Central Board of Direct Taxes (CBDT) has released a Notification No. 31/2021 which include the changes of CbC reporting threshold. Accordingly, the threshold for CbC reporting has been increased from INR 55 billion (5,500 crore) to INR 64 billion (6,400 crore) which is consolidated group revenue of MNE in the preceding year. See the story in Regfollower |
| Indonesia | CbC reporting requirement-General rule: On 4 March 2021, the Indonesian Directorate General of Taxation (DGT) updated the XML schema (version 2.0) for country-by-country reports (CbCR). See the story in Regfollower |
| Israel | Filing deadlines: On 7 April 2021, the tax authority of Israel extends the deadline for submitting annual income tax return to 30 June 2021. The extension is applicable for the tax year 2020. See the story in Regfollower |
| Malta | Adjustments-Primary adjustment: On 16 April 2021, Malta has published and enacted Act to implement Budget Measures for the Financial Year 2021and other administrative measures (Act No. XVIII of 2021). The budget added the Article 51A providing the power to the MOF to make transfer pricing adjustment regarding arm’s length price. See the story in Regfollower |
| Norway | Filing deadlines: On 6 April 2021, the Norway extends the filing deadline for corporate income tax returns from 31 May 2021 to 20 August 2021 due to coronavirus pandemic. See the story in Regfollower |
| Poland | Adjustments-Primary adjustment: On 2 April 2021, the Polish Ministry of Finance has published tax clarifications on transfer pricing regarding the adjustment of transfer prices within the meaning of Art. 11e of the CIT Act (Article 23q of the PIT Act), in relation to the provisions in force from January 1, 2019. See the story in Regfollower |
| Spain | Scope of transfer pricing rules: On 13 April 2021, the Spanish tax agency has approved the forms (Model 234, 235 & 236) regarding cross-border reporting arrangement under DAC6. In this regard, the tax agency published an Order HAC / 342/2021. See the story in Regfollower Scope of transfer pricing rules: On 7 April 2021, the Spanish Official Gazette published the Royal Decree No. 243/2021 providing details rules and procedures including- taxpayers and intermediaries’ obligation in relation to cross-border tax arrangements. See the story in Regfollower |
| US | APAs-General rules: On 15 April 2021, the IRS released an updated memo on e-signature requirements extending the authorization to electronically sign a large number of IRS forms until Dec. 31, 2021, and adding a number of new forms. See the story in Regfollower |
Transfer Pricing Brief: May 2021
May 11, 2021
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