| Botswana | Documentation-Thresholds: On 1 September 2021, the General Commissioner published a ruling which sets the threshold for the preparation and submission of transfer pricing documentation. Accordingly, the obligation to prepare and submit transfer pricing documentation will be exempted if the “cumulative arm’s length value” of the transactions with related parties does not exceed 5 million BWP in a tax year. See the story in Regfollower |
| Colombia | Main corporate income tax rate: On 14 September 2021, Colombia has approved the new Tax Reform Bill 2021 (Law No. 2155 of 2021) which propose to increase the CIT rate to 35% from 2022. The new Colombia tax reform adds an additional 3% to companies in the financial sector between 2022 and 2025, which means these companies will pay 38% to CIT. See the story in Regfollower |
| Cyprus | Filing deadlines: On 24 September 2021, Cyprus’s Ministry of Finance has issued a decree providing further extension of electronic submission of tax returns for business (TD4) and personal (TD1A) for the fiscal year 2019. The new deadline is 30 November 2021. See the story in Regfollower Scope of transfer pricing rules: On 21 September 2021, the Tax Department of Cyprus has issued a notice extending the DAC6 reporting deadlines until the 30th November 2021 subject to certain conditions. See the story in Regfollower |
| Finland | Restriction on interest deduction: On 9 September 2021, the Ministry of Finance of Finland has released the government’s budget proposal for 2022. Accordingly, restrictions on interest rate deductions will be eliminated for public infrastructure projects. Adjustments: The Budget 2022 propose to revise transfer pricing adjustment provision beginning from 2022 so that it can be applied within the scope of the OECD Transfer Pricing Guidelines. See the story in Regfollower |
| Germany | MAP: On 27 August 2021, the Federal Ministry of Finance published guidance on mutual agreement (MAP) and arbitration procedures. The guide explains how to initiate procedures, how to carry out procedures, how to execute agreements, etc. See the story in Regfollower |
| India | Transfer pricing information return: On 9 September 2021, the Central Board of Direct Taxes (CBDT) has issued a press release extending the due date for filing the tax audit report and transfer pricing certificate to 15 January 2022 and 31 January 2022, respectively. See the story in Regfollower |
| Ireland | Scope of transfer pricing rules: On 6 September 2021, the Revenue updated its guidance to assist some qualifying companies in accordance with Section 110 regarding the application of transfer pricing (TP) rules and other issues. See the story in Regfollower |
| Jordan | Transfer pricing information return: On 16 September 2021, Jordan has published Executive Instructions No. 3 of 2021 regarding new transfer pricing (TP) rules for MNE groups. Accordingly, taxpayers with related party transactions equal to JOD 500,000 or more in a 12-month period are required to submit a transfer pricing disclosure with the annual tax return. CbC reporting requirement-Thresholds: Multinational Enterprises (MNEs) exceeding consolidated revenue exceeding a JOD 600 million in the previous year, will be required to submit a CbC (Country-by-Country) report. The CbC report must be submitted within 12 months after the end of the tax year. See the story in Regfollower |
| Malaysia | CbC reporting requirement-Deadlines: On 13 September 2021, the Inland Revenue Board of Malaysia (IRBM) has published the updated “frequently asked questions on tax matters during the national recovery plan”. Accordingly, companies in Malaysia responsible for filing the CbCR report may request an extension of the filing deadline if the reporting fiscal year falls within the National Recovery Plan period. See the story in Regfollower |
| Mexico | Transfer pricing information return: On 8 September 2021, the Mexican Executive Branch has submitted Economic Package for the fiscal year 2022 including a proposal of Tax Reform. Accordingly, information return reporting regarding transactions with related parties would be due no later than 15 May instead of 31 December of the immediately succeeding year. See the story in Regfollower |
| Peru | CbC reporting requirement-Deadlines: US parent entities located in Peru will be required secondary filing by mid-October 2021 for the fiscal year 2020 since there is no automatic exchange of CbC reporting agreement between Peru and the US. See the story in Regfollower |
| Philippines | Digital economy transactions-General: On 21 September 2021, the House of Representatives approved on final reading a proposal imposing a 12% value-added tax (VAT) on digital transactions in the country to generate new funding sources for the country’s Covid-19 response efforts. See the story in Regfollower |
| Ukraine | CbC-Master file & Local file: On 20 August 2021, the Ukraine Ministry of Finance issued Order № 479 providing guidance of new transfer pricing documentation requirements, including the Local file, Master file, and Country-by-Country (CbC) report requirements that generally apply from 2021, as well as the requirement to submit the notice of participation in an international group of companies (i.e., MNE group). Documentation-Timing and deadlines: On 20 August 2021, the Ukraine Ministry of Finance issued Order № 478 clarifying temporary suspension of the deadline for taxpayers to respond to the requests of regulatory authorities to submit documentation on transfer pricing. See the story in Regfollower |
Transfer Pricing Brief: October 2021
October 04, 2021
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