GreeceCbC reporting requirement: On 17 September 2019, the Greek Public Revenue Authority (AADE) released a Circular 1341 / 09-09-2019 containing amendments regarding the submission process of CbC notifications. Under this new Circular, notification of CbC reports are to be submitted through an electronic application on the AADE website from 15 October 2019 instead of submitting notifications via email.
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BelgiumSpecific TP compliance: On 24 September 2019, the Belgian Ruling Commission published a newsflash on its website regarding (pre-) filing requests for rulings in respect of transfer pricing, the patent income deduction and the innovation income deduction.
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UkraineAudit Rules: On 6 September 2019, the Ukrainian Ministry of Finance (MOF) has published Order No. 307 of 16 July 2019 in the official gazette amending Order No. 399 of 30 March 2017. The amendment clarifies the procedures to audit compliance with the arm’s length principle.
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PhilippinesAudit Process: On 20 August 2019, the Bureau of Internal Revenue (BIR) issued a transfer pricing audit guidelines under revenue audit memorandum order (RAMO) No. 1-2019. The guideline provides standardized audit procedures and techniques applicable to taxpayers with related-party & or intra-company transactions.
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PortugalTransfer Pricing-Rule: On 18 September 2019, the Portuguese Government officially published the Law no.119/2019 that introduces changes to various tax codes, including significant amendments to current transfer pricing legislation. The changes impact the use of transfer pricing methods, documentation requirements, and Advance Pricing Agreements.
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AustraliaSafe Harbour-Simplified interest rates: On 11 September 2019, the Australian Taxation Office (ATO) released an updated version of Practical Compliance Guideline (PCG) 2017/2 concerning the eligibility criteria for applying simplified transfer pricing record keeping options for low-level related party inbound and outbound loans.
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ItalyIntangible property-General: On 9 September 2019, Italy published a resolution No, 81/E amending the patent box regime made by Law Decree No. 34 of 30 April 2019, which entered into force on 1 May 2019.
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IndiaTransfer Pricing-Rule: On 13 September 2019, the Central Board of Direct Taxes (CBDT) published Notification No. 64/2019, which sets a tolerance range for the variation between the arm’s length price and the transaction price for the 2019-20 assessment year.
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Saudi ArabiaMaster file/Local file: Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia requested the taxpayers to submit specific transfer pricing (TP) documentation (master file and local file) in relation to the fiscal year ending 31 December 2018.
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Romania CbC reporting requirement-General rule: On 19 August 2019, Romania published Order No. 2.273, amending the rules on submission of Country-by-Country (CbC) reports and notifications, effective from 26 August 2019. Now both CbC reports and notifications must be submitted through online submission platform.
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RussiaSafe Harbour-Simplified interest rates: On 6 September 2019, the Russian Central Bank announced the decision to reduce the key rate from 7.25% to 7.00% with effect from 9 September 2019. For tax purposes, the key rate is important in relation to the safe harbor rates for interest income and expense on controlled debt.
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Comparable uncontrolled price method (“CUP”): On 2 September 2019, the Federal Tax Service (FTS) of Russia published a Letter No. CA-4-7/17555, about the review of litigation regarding tax control in the field of transfer pricing.
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FranceRestriction on interest deduction: On 4 September 2019, the French General Directorate of Public Finance issued a ruling regarding the deductibility of interest paid to a related Belgian company benefiting from the notional interest regime.
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Hong KongBEPS related compliance: On 28 August 2019, the Hong Kong Inland Revenue Department published a webpage explaining the requirements in relation to master file and local file, and the Department’s approach to ensure compliance with the requirements. The requirements relating to master file and local file apply in relation to an accounting period beginning on or after 1 April 2018.
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LuxembourgSpecific TP compliance: On 8 August 2019, the draft law 7465 was submitted to the parliament in order to implement the EU mandatory disclosures rules and exchange of information on cross-border tax arrangements. Qualifying intermediaries such as financial and tax advisers, lawyers, banks, accountants and domiciliation service providers need to report certain arrangements to the relevant tax authorities.
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