It is our pleasure to present to you the first edition of our WTS Transfer Pricing Newsletter for 2020. Certainly, the global economic and social impacts of the coronavirus disease (COVID-19) are the key news these days. WTS Global has created an overview of the measures taken by various countries to respond to the tax aspects of this crisis, which can be found at the following link: https://wts.com/global/insights/covid19
Apart from this, the current issue of the WTS Transfer Pricing Newsletter provides you with an update on the recent news and cases in the field of transfer pricing in 14 countries as well as an OECD update on Pillar 1.
Europe
Austria has implemented the EU directive on tax dispute resolution mechanisms into local law.
Our Belgian colleagues discuss the recently published circular letter of the Belgian tax administration grouped under three main takeaways, one being the retroactive entry into force.
In Germany, recent decisions of the German Federal Fiscal Court revised a decade-long jurisprudence on I/C financing relations, implicating that group support no longer rep-resents a valuable arm’s length security.
Two recent Court decisions in Italy deal with the applicability of the full range of bench-marking studies to be compliant with the arm’s length principle.
Poland has introduced the obligation to prepare a transfer pricing information (TP R) report to increase the effectiveness of the transfer pricing controls.
DAC 6 requirements were implemented into local law in Romania, and Serbia changed the rulebook on transfer pricing related to the treatment of purchasing fixed assets.
Via Presidential Decree no. 2151 (dated 25 February) several important amendments were made on the Turkish corporate income tax code following the OECD BEPS Action 13 recom-mendations.
The three-tier approach and BEPS Action 13 recommendations were also implemented into Ukrainian law on 16 January, resulting in considerable amendments to the Ukrainian tax code.
Rest of world
Argentina postponed the deadlines for filing the transfer pricing documentation for the FYs 2018 and 2019 until 18 May. In addition, a new draft transfer pricing regulation is currently under review.
Brazil could see the implementation of a major transfer pricing reform, as Brazil is discuss-ing the option to align the Brazilian transfer pricing rules with the OECD standard.
The latest transfer pricing regulations of Senegal are being presented with respect to transfer pricing documentation and CbCR.
Thailand’s Revenue Department has announced specific requirements for companies that are obligated under the transfer pricing act to prepare a documentation with affiliated companies.
Since TP audits are getting more attention in Vietnam, the importance and practical signifi-cance of the APA is increasing.
The taxation of digital business models is one of the key topics these days. Therefore, the OECD has published a consultation document (Pillar 1) with many important aspects regarding this topic which are summarised by our digitalisation experts.
If you have any questions regarding any aspects of this newsletter, our Global Transfer Pricing experts will be happy to answer them.
