| Austria | Scope of transfer pricing rules: On 21 October 2020, the Finance Ministry published final guidance of cross border arrangements (DAC6) including definition of terms, reportable arrangements, hallmarks and main benefit test, deadlines for reporting, etc. See the story in Regfollower |
| Belarus | Information exchange-Multilateral: On 14 October 2020, Belarus has published Resolution No. 590 on the National Legal Internet Portal, through which Belarus is set to join the Global Forum on Transparency and Exchange of Information for Tax Purposes. See the story in Regfollower |
| Belgium | Compliance-Filing deadlines: On 12 October 2020, the Ministry of Finance declared further extension of the deadline for filing corporate income tax (CIT) return to 16 November 2020 for Assessment Year 2020. See the story in Regfollower |
| Colombia | MAP: On 21 August 2020, the Colombian National Tax Authority has issued Resolution No. 000085 in the official gazette which establishes Mutual Agreement Procedure (MAP) to avoid double taxation and prevent evasion in Colombia. See the story in Regfollower |
| Costa Rica | Restriction on interest deduction: On 15 October 2020, Costa Rica published Resolution DGT-R-0032-2020, which outlines the application process for the taxpayer to increase the maximum deduction limit for net interest expense. See the story in Regfollower |
| Czech Republic | Digital economy transactions-General: The Government decided to introduce a domestic digital service tax. Companies with a global turnover of EUR 750 million, including on turnover from digital advertising, the sale of user data, and intermediation services are subject to 7% DST rate. See the story in Regfollower |
| Egypt | Master file/Local file-Threshold: On 19 October 2020, Egyptian approved a unified tax procedures law (Law no. 206 of 2020). The Law stipulates that the taxpayers must prepare and submit Master file and Local file if their total related party transactions exceed EGP 8 million during a tax period. See the story in Regfollower |
| France | Digital economy transactions-General: France intends to collect the country’s digital services tax in December 2020, which was due in April and October 2020. See the story in Regfollower |
| Hong Kong | CbC reporting requirement-General rule: On 6 October 2020, Inland Revenue Department of Hong Kong has published the updated CbC reports XML schema and user guide. From 1 February 2021, data files must be prepared using CbC Return XML Schema (version 2.0). Up to 31 January 2021, data files must be prepared using CbC Return XML Schema (version 1.0). See the story in Regfollower |
| India | Compliance-Filing deadlines: On 24 October 2020, the Indian Finance Ministry published a notice regarding further extension of due date for furnishing of Income Tax Returns for the taxpayers who are required to furnish report in respect of international/specified domestic transactions to 31st January, 2021. See the story in Regfollower Comparability-Range: On 19 October 2020, India’s Central Board of Direct Taxes has released the Notification No. 83/2020 setting the arm’s length pricing variation limit for assessment year 2020-21. See the story in Regfollower |
| Indonesia | APAs-General rules: On 17 September 2020, the Indonesian Directorate General of Taxation published a Regulation No. PER- 17/PJ/2020 regarding the procedures for completing applications, implementing, and evaluating an advance pricing agreement (APA). See the story in Regfollower |
| Ireland | Restriction on interest deduction: Ireland has a plan to consult with stakeholders in 2021 with the intent to enact ATAD-compliant interest limitation rules in Finance Bill 2021, taking effect from 1 January 2022. The rule limits current period tax deductions for related party interest up to 30% of taxable EBITDA. See the story in Regfollower |
| Israel | Documentation-CbC reporting requirement: On 12 October 2020, the Israeli Tax Authority (ITA) published a draft bill for public consultation proposing to incorporates the principles of the OECD’s BEPS Action 13. See the story in Regfollower |
| Italy | CbC reporting requirement-General rule: The Italian tax authorities updated the technical rules and filing instructions to submit country-by-country (CbC) reports in accordance with the OECD’s CbC XML schema adopted in June 2019. See the story in Regfollower |
| Jordan | Compliance with BEPS standards: On 29 September 2020, Jordan deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) with the OECD. See the story in Regfollower |
| Luxembourg | Scope of transfer pricing rules: On 14 October 2020, the Luxembourg Tax Administration has issued updated guidelines concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) as per Council Directive (EU) 2018/822 of 25 May 2018. See the story in Regfollower |
| Peru | Information exchange-Multilateral: On 21 October 2020, the Peruvian tax authorities has announced that they will start the CRS Multilateral Competent Authority Agreement (CRS MCAA) with more than 130 countries beginning in 2021. See the story in Regfollower CbC reporting requirement-Deadlines: On 25 September 2020, the Peruvian tax authority released a Resolution No. 000155-2020/SUNAT extending the deadline to submit the 2019 country-by-country (CbC) reports for specific entities. See the story in Regfollower |
| South Korea | MAP: On 20 October 2020, South Korea’s National Tax Service (NTS) has released updated Mutual Agreement Procedure (MAP) guidance on the official website. See the story in Regfollower |
| Spain | Digital economy transactions-General: On 16 October 2020, the Spanish Official Gazette published the Laws Nos. 4/2020 and 5/2020, implementing a digital services tax and a financial transactions tax. See the story in Regfollower |
| Sri Lanka | Transfer pricing information return: The Inland Revenue Department (IRD) has published the transfer pricing (TP) disclosure form and guide for the assessment year (AY) 2019/2020. Taxpayers are required to complete this form if they have conducted controlled transactions with related parties equal to or more than LKR 200 million during the year. See the story in Regfollower |
| US | APAs-General rules: On 28 October 2020, the Internal Revenue Service (IRS) is updating parameters that the Advance Pricing and Mutual Agreement program (APMA) officials has to be followed in implementing MAP/APA resolutions negotiated under US tax treaties. See the story in Regfollower |
| Zambia | Documentation-Thresholds: On 25 September 2020, the Minister of Finance (MOF) presented the budget for 2020 to the National Assembly. The budget includes the proposal to increase the threshold to ZMW 50 million from ZMW 20 million for local companies that are not required to provide transfer pricing documentation. See the story in Regfollower |
Transfer Pricing Brief: November 2020
November 06, 2020
Share This
