| Austria | Documentation-Requirement: On 7 October 2021, the Austrian Ministry of Finance published the updated Austrian Transfer Pricing Guidelines (Austrian Guidelines) 2021. The guideline provided guidance for those companies which fall under the legal obligation to prepare transfer pricing documentation in Austria. See the story in Regfollower |
| Cyprus | Information exchange-Bilateral: On 7 October 2021, the Cyprus Tax Department informs all legal entities and their representatives that the bilateral Competent Authority Arrangement (CAA) for the exchange of CbC reports between Cyprus and the USA which is currently under negotiation, is expected to be effective for Reporting Fiscal Years starting on or after 1 January 2021. See the story in Regfollower |
| Denmark | Documentation-Requirement: On 6 October 2021, the Danish parliament is taking into account draft bill L 7, which proposed an amendment to the Danish Tax Control Act in order to relax the documentation requirements for transfer pricing for purely Danish transactions. Accordingly, no TP documentation is required for transactions between Danish group companies that are subject to ordinary corporate taxation. See the story in Regfollower |
| Dominican Republic | CbC reporting requirement-General rule: On 5 October 2021, the Government established specific regulations for the country-by-country report through general standard on August 2021. Under this general rule, the materiality threshold and assumptions for the filing of the CbC Report is established. See the story in Regfollower |
| Germany | Restriction on interest deduction: On 21 October 2021, the German Ministry of Finance released Tax Court Decision No. IR 4/17(dated 18 May 2021), regarding the calculation of an arm’s-length interest rate on intercompany loans. Under the ruling, the interest rate should be based on the economic circumstances of the borrower (and not the lender). See the story in Regfollower |
| India | Safe harbor-Rule: On 24 September 2021, the CBDT issued a new Notification No. 117/2021, to extend the applicability of the transfer pricing safe harbor rules. The extension applies for the 2020-21 and 2021-22 assessment years. The due date for filing is 28 February 2022. See the story in Regfollower |
| Namibia | Compliance with BEPS standards: On 30 September 2021, Namibia has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, becoming the 96th jurisdiction to join the Convention. See the story in Regfollower |
| Puerto Rico | Transfer pricing information return: On 20 September 2021, the Puerto Rico Treasury Department (PRTD) has issued Administrative Determination (AD) No. 21-08, which amends AD No. 21-05 of 11 May 2021. The AD 21-08 clarifies guidance on submitting transfer pricing studies (TPS). See the story in Regfollower |
| Serbia | CbC reporting requirement-General rule: On 1 October 2021, the Serbian Ministry of Finance has published the rulebook updating transfer pricing rules including more detailed guidance regarding CbC report including the conditions, content, and manner of submitting the report on controlled transactions of an international group of related legal entities. See the story in Regfollower |
| Singapore | MAP: On 23 October 2021, the Inland Revenue Authority of Singapore (IRAS) issued an updated edition of its e-tax guide on “avoidance of double taxation agreements” providing guidance on mutual agreement procedure (“MAP”) under Singapore’s DTAs. See the story in Regfollower |
| Spain | Compliance with BEPS standards: On 28 September 2021, Spain deposited its instrument of ratification for the BEPS MLI. On 7 June 2017, Spain signed this convention and the MLI will enter into force on 1 January 2022 for Spain. See the story in Regfollower |
| Thailand | CbC reporting requirement-General rule: On 15 October 2021, the Thai Revenue Department released guidance concerning the transfer pricing requirements with regard to country-by-country (CbC) reporting for accounting periods beginning on or after 1 January 2021. The guidance is referred to as Notification of the Director-General on Income Tax No. 408 (dated 30 September 2021). See the story in Regfollower Local file-General rule: On 30 September 2021, the Director-General of the Thai Revenue Department issued guidance Notification No. 407 regarding transfer pricing (TP) documentation requirements for the information and documentation for the Local file and exemption from the benchmarking study requirement. These new measures are effective for all accounting periods beginning on or after 1 January 2021. See the story in Regfollower |
| Turkey | MAP: On 26 October 2021, Turkey has published Law No. 7338 on Certain Amendments on Tax Procedural Law and Certain Laws in the Official Gazette which clarifies provisions with respect to the domestic application of the mutual agreement procedure (MAP). The Law has introduced a new section entitled ‘Mutual Agreement Procedure’ in the Tax Procedural Law No. 213. See the story in Regfollower |
Transfer Pricing Brief: November 2021
November 02, 2021
Share This
