| Bulgaria | Compliance with BEPS standards: On 15 April 2022, Parliament is considering a bill to ratify the Multilateral Convention Implementing Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (MLI). See the story in Regfollower |
| Bolivia | Filing deadlines: On 22 April 2022, the Tax Administration published a guidance RND No. 102200000008, which extends the deadline until 31 May 2022 for filing certain corporate tax reports and statements, for the tax period closing 31 December 2021. See the story in Regfollower |
| Brazil | Scope of transfer pricing rules: On 12 April 2022 an event was held to present the outline of the new transfer pricing rules drafted by Brazil following a consultation process with the OECD. The scope of the rules is widened to include all transactions between related parties whereas the previous system applied only to imports, exports and loans. Applicable methods: All the OECD transfer pricing methods are to be introduced, including the TNMM and the transactional profit split method, and the most appropriate method should be selected. Primary adjustment: Primary adjustments will be possible for the tax administration. Elimination of double taxation will be possible through corresponding adjustments. The mutual agreement procedure will be available to resolve issues. Documentation: Transfer pricing documentation will be in line with best practice. In addition to country-by-country reporting which is already in operation there will be provision for the complete three-tiered documentation including a master file and local file. See the story in Regfollower |
| Greece | Restriction on interest deduction: On 28 March 2022, Government published Law No. 4916/2022, which establishes new group escape, rules for the 30% of EBITDA interest deduction restriction. The new group scape rule was made optional when the Greek interest restriction rules were introduced on 1 January 2019 in line with the EU Anti-Tax Avoidance Directive (ATAD). The new group escape rules are generally effective from 28 March 2022. See the story in Regfollower |
| Ireland | Scope of transfer pricing rules: On 1 April 2022, the Revenue published an eBrief No. 078/22, which updates a manual regarding mandatory disclosure of reportable cross-border arrangements (DAC6). See the story in Regfollower |
| Kenya | Scope of transfer pricing rules: On 12 April 2022, the Finance Bill 2022 was presented in the National Assembly of Kenya. The Bill aims to broaden the scope of transactions falling within the scope of transfer pricing by including non-resident persons operating under the preferential tax regime. CbC reporting requirement: The Bill proposes to introduce CbC documentation requirement for MNEs resident in Kenya in line with OECD BEPS Action 13. The Bill prescribes the turnover threshold requirement of KES 95 billion including extraordinary or capital gains. Master file/Local file: The Finance bill also proposes to require submit local file and master file for MNE’s resident in Kenya no later than six months after the last day of the multinational’s reporting financial year. Digital economy transactions-General: The Bill proposes to increase the digital service tax rate from 1.5% to 3% of the gross transaction value. See the story in Regfollower |
| Luxembourg | Restriction on interest deduction: On 25 March 2022, the Luxembourg Tax Authority updated Circular L.I.R. n° 168bis/1 (French) which clarifies certain aspects of the interest expense deduction limitation rules included in article 168bis of the Luxembourg Income Tax Law (ITL). See the story in Regfollower |
| Oman | CbC reporting requirement: In March, the Tax Authority published guidance clarifying the country-by-country (CbC) reporting requirements of multinational corporations (MNEs) operating in Oman. The guide provides a general overview of the CbC reporting requirements as part of the BEPS Action 13 report. See the story in Regfollower |
| Paraguay | Documentation-Requirement: On 7 April 2022, the tax authority of Paraguay has issued General Resolution No. 115/2022, which provides detailed rules on the preparation and submission of the transfer pricing (TP) reporting requirements as per Law No. 6380/2019 and regulated by Decree No. 4644/2020. See the story in Regfollower |
| Peru | Applicable methods-Other methods: On 26 March 2022, Peru issued Legislative Decree No. 1537 in the official gazette regarding relaxing the term for the presentation of the communication of exported and imported goods and the obligation of the information to be registered in said communication. The rules apply in relation to the transfer pricing (TP) ‘sixth method’ and will effect from 1 January 2023. See the story in Regfollower |
Transfer Pricing Brief: May 2022
May 05, 2022
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