WTS. Transfer Pricing Newsletter 2021 No. 2.

Navigating regulatory compliance: key steps for businesses

Dear Reader, It is our pleasure to present to you the second edition of our WTS Transfer Pricing newsletter for 2021. In this edition, colleagues from 16 countries provide an update on recently introduced legislations and cases, specifically the adoption of certain OECD Guidelines. Additionally, developments in the field of transfer pricing, including the implementation of the BEPS project into the laws of various countries, are presented.

Europe

• Austria: The draft of the revised Austrian Transfer Pricing Guidelines 2020 was published.

  
  

• France: After half a century, the tax regime regarding intangible assets is changed under the newly established “Nexus” approach.

  
  

• Germany: The Federal Ministry of Finance has published the Administrative Principles 2020, with a greater emphasis on procedural aspects.

  
  

• Hungary: Our colleagues explain the current focus of the Hungarian tax authority at Hungarian subsidiaries of foreign companies following the COVID-19 crisis.

  
  

• Italy: New rules came into force regarding the structure, content, and submission of transfer pricing documentation (Master File and Local File).

  
  

• The Netherlands: A draft proposal was published to limit downward adjustments and address transfer pricing mismatches.

  
  

• Poland: New documentation requirements for transactions involving tax havens have been issued.

  
  

• United Kingdom: The government has opened a consultation process on changes regarding the transfer pricing documentation requirements.

  
  

Further Countries

• Argentina: Our professionals provide an overview of the new mandatory disclosure framework for domestic and international tax planning arrangements.

  
  

• Brazil: New transfer pricing documentation requirements have been announced, requiring significant effort to align with international standards.

  
  

• Chile: A decisive tax court ruling against the tax administration could bring profound changes to the local transfer pricing regulatory framework.

  
  

• China: A consultation paper has been published that shortens the APA process to just three steps to provide faster tax certainty.

  
  

• Ghana, India, Senegal, and Vietnam: New regulations and reforms are reported that capture key BEPS action items to provide greater tax certainty.

  
  

Yours sincerely,

WTS Global Transfer Pricing Team