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Global
- OECD releases consultation document with proposed changes to Commentaries to OECD Model Tax Convention on Article 9 (Associated Enterprises) and related articles – click here
- Making tax dispute resolution more effective: New peer review assessments for Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand and Portugal – click here
- Leaked copy of US proposal for Pillar One and Two multinational group tax reforms available – click here
- Despite the pandemic, 2020 US APA report shows increase in executed APAs and decreased processing times – click here
- This week in tax: G20 moves towards a global tax reform – click here
- Avery Dennison wins Chile transfer pricing dispute over intercompany loans, distributor margin – click here
- Argentine entities with controlling ultimate parent entities in the United States should determine whether they have to file the local CbC report – click here
- China STA issues consultation draft on simplified procedure for unilateral APAs – click here
- China clarifies procedures for processing payments for transfer pricing adjustments – click here
- India reduces transfer pricing filing burdens, increases reporting thresholds – click here
- Zambia: Amendments to country-by-country reporting rules – click here
- Nigeria: Transfer pricing awareness survey (KPMG report) – click here
DAC6
- Access the DAC6 Comparison Tool App that allows the user to make instant comparisons among DAC6 provisions in different countries. Plus, it offers direct links to each local legislation and guidelines and shows you how to perform the MBT test – click https://comparison.dac6guide.eu/
- For the latest developments and news concerning DAC6 – click here
Romania
- For now, we have two stars on the impact with Europe. And a question from Brussels: Do you have no ambition? (RO) – click here
- Daniel Dăianu: The Romanian fiscal system is deeply unfair. Those who teach us how to have an optimal procedure should help us fight massive profit-shifting (RO) – click here
- Approaching transactions in the context of the COVID-19 pandemic. What has changed in the last year? What is important to keep in mind when entering into a transaction during this period? (RO) – click here
Europe
- Danish Ministry of Taxation admits defeat in important transfer pricing case – click here
- UK: Proposals for new transfer pricing documentation, new annual related-party transaction return – click here
- Switzerland: Tax authorities challenge transfer pricing of asset management offshore structures – click here
- Belarus: Review of transfer pricing measures effective in 2021 – click here
