Global Transfer Pricing Newsletter #1/2021

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

It is our pleasure to present to you the first edition of our WTS Transfer Pricing newsletter for 2021.

In this latest edition, our colleagues from 13 countries provided an update on recently introduced legislations and cases; in particular, the adoption of certain OECD guidelines. Additional developments in the field of transfer pricing, including the implementation of the BEPS into the laws of the various countries, are presented.


In France, to deduct the full amount of intergroup interests, a French company must prove that the paid interests are not excessive. Our French colleagues outline some of the principles behind this regulation.

In Spain, the settlement of tax disputes in the European Union has been implemented into Spanish domestic law.

The Swedish Tax Agency has issued new guidance on financial guarantees. Swedish taxpayers can now rely on the OECD approach as suggested in Chapter X.

Our Ukraine colleagues explain Law 466-IX that has introduced comprehensive changes within the Ukrainian tax code, including the implementation of the BEPS three-tier reporting standard.

Further Countries

In Argentina, the Argentine Revenue Service has added new transfer pricing documentation requirements for operations with intermediaries. More specifically, the requirements for transfer pricing documentations have been extended with a focus on imports and exports through international intermediaries.

Chile’s Internal Revenue Service published Resolution 101, which incorporates two new affidavits regarding transfer pricing compliance, which must be submitted by the taxpayer in certain cases.

For full update on recently introduced legislations and cases in 13 countries, please download here


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