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2021

#3/2021

WTS Transfer Pricing

Newsletter

Transfer Pricing Newsletter: Update on the recent news and cases in 15 countries

#2/2021

WTS Transfer Pricing

Newsletter

Transfer Pricing Newsletter: Update on the recent news and cases in 16 countries

#1/2021

WTS Transfer Pricing

Newsletter

Transfer Pricing Newsletter: Update on the recent news and cases in 13 countries

Transfer Pricing Newsletter: Update on the recent news and cases in 15 countries

Europe

Austria: New Austrian Transfer Pricing Guidelines 2021

Belgium: Belgian Transfer Pricing court case: a rare occurrence

France: The Engie Case: an ambitious new approach by the French Tax Administration

Germany: German Federal Ministry of Finance: Administrative Principles 2021 on Transfer Pricing published

Germany: Recent changes on German Tax Law concerning Transfer Pricing

Ukraine: State Tax Service intensifies TP control

Further Countries

Argentina: Transfer Pricing developments in Argentina

Benin: Transfer Pricing Update Benin

Chile: Migration of the approach of the Chilean Revenue Service to segments with greater fiscal impact

China: Responses to practical questions on the Transfer Pricing implications of the COVID-19 impacts15

Nigeria: Transfer Pricing Update on Nigerian TP case

Senegal: Implementation of Action 12 of BEPS project: a strengthened internal tax system

Taiwan: Supreme Administrative Court decides on one-time Transfer Pricing adjustments

Thailand: TP legal framework and practical insights

United States: The US’ role in global adoption of Pillar 1 and Pillar 2 / ongoing conversations in the US on tax reform / a status update on US tax reform

Vietnam: Transfer Pricing Update Vietnam
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Transfer Pricing Newsletter: Update on the recent news and cases in 16 countries

Europe

Austria: New Austrian Transfer Pricing Guidelines 2020

France: Self-financing through intangible assets or how to generate significant tax savings

Germany: German Federal Ministry of Finance: Administrative Principles 2020 published

Hungary: Pandemic does not stop TP audits in Hungary

Italy: New Rules on the Transfer Pricing Documentation

The Netherlands: Proposed limitation to Dutch unilateral downward adjustments

Poland: New documentation requirements for transactions with tax havens as of 1 January 2021

UK: UK Consultation on Transfer Pricing Documentation

Further Countries

Argentina: Mandatory Disclosure Framework and Transfer Pricing

Brazil: New ‘Local File’ Requirements in Brazil

Chile: Recent cases on TP – Chile vs Avery Dennison Chile SA (FY 2012)

China: China releases public consultation paper on simplified unilateral APA procedures

Ghana: Ghana introduces new Transfer Pricing Regulations

India: Transfer Pricing Update India

Senegal: Latest Transfer Pricing tax reform implementing Action 12 of the OECD BEPS project

Vietnam: The regulations on the Advance Pricing Agreement (“APA”) and its modification
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Transfer Pricing Newsletter: Update on the recent news and cases in 13 countries

Europe

France: Proof of the interest rate applied between related companies

Spain: Transposition of directive 2017/1852, of the council of 10 October 2017, relating to the integration of mechanisms or the resolution of tax disputes in the European Union into Spanish domestic law

Sweden: New guidance on financial guarantees

Ukraine: New business purpose test in Ukrainian tax law

Further Countries

Argentina: Argentina adds new transfer pricing documentation requirements for operations with intermediaries

Chile: Adoption of new transfer pricing requirements: master file & local file

Costa Rica: Transfer pricing update for Costa Rica

India: Updates on the Mutual Agreement Procedure (MAP)

China publishes annual APA report

Nigeria: Averting penalties on TP transactions by means of proper TP compliance

Senegal: The Multilateral Convention of OECD BEPS project: Senegal’s position and its impact on its bilateral DTTs

Taiwan: Draft amendments to transfer pricing assessment rule

Vietnam: New decrees on transfer pricing
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