WTS Global – Transfer Pricing Newsletter #2/2020

Global Transfer Pricing Newsletter #2/2020

An update on the recent news and cases in the field of transfer pricing in 13 countries

Our French colleagues explain what needs to be considered from a transfer pricing perspective in these times
of COVID-19, especially with regard to documentation requirements, the use of benchmarking studies and the
deductibility of interest expenses.

The tax consequences of the German draft law on intercompany financing are compared and discussed both in
a purely domestic as well as a cross-border scenario.

Hungary provided its taxpayers a four-month extension of their transfer pricing documentation and furthermore
accepts a reevaluation of the profit-loss model, due to the impact of COVID-19.

In Italy, a new Legislative Decree came into force to ensure a more effective EU transfer pricing dispute resolution
mechanism.

In an example, our colleagues from the Netherlands describe the field of tension in which the OECD regulations and
Dutch tax laws on the deductibility of intra-company financing are currently moving.

Ukraine recently introduced new proportional adjustment rules, which could lead to a reduced risk of double taxation
triggered by one-sided TP adjustments.

Our colleagues from Argentina provide an overview of the new transfer pricing regulations by summarizing the six main
aspects of GR4717.

Despite the modernised Income Tax Law and Tax Code, which has been published at the beginning of this year, Chile
expects further practical and regulatory modifications due to the ongoing COVID-19 pandem

The contribution from Nigeria sheds light on the first transfer pricing decision of the Nigerian tax appeals tribunal and
provides a brief outlook on what taxpayers should consider in view of their transfer pricing.

Pakistan shifted the focus of its Tax Authorities towards transfer pricing issues by introducing regulatory amendments
concerning TP audits.

Since the beginning of 2020, reduced limitations on Taiwan’s “one-time transfer pricing adjustment” became effective,
which helps enterprises to achieve an arm’s-length resulteven in times of unexpected market conditions.

Thailand extended the deadline for the 2019 tax return until 31 August 2020 and recently signed the “Multilateral
Convention on Mutual Administrative Assistance in Tax Matters” on 3 June 2020, which will likely lead to stricter
documentation requirements.

Vietnam enhances its focus on transfer pricing by introducing the new “Law on Tax Adminis-trations” and thereby
changing existing regulations on the deduction of loan interest costs – alongside other TP-related innovations.

For detail information, please see here

WTS Global Team