Global Transfer Pricing Newsletter #2/2021

An update on the recent news and cases in the field of transfer pricing in 16 countries

It is our pleasure to present to you the second edition of our WTS Global Transfer Pricing Newsletter for 2021.

In the latest edition of the WTS Global Transfer Pricing Newsletter, our 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 the various countries are presented.

Europe

In Austria, the draft of the revised Austrian Transfer Pricing Guidelines 2020 was published. Our Austrian colleagues outline the changes and consequences.

In France, after half a century, the status quo of the tax regime regarding intangible assets is changed. Our French colleagues outline some of the principles behind the newly established “Nexus” approach.

In Germany, the Federal Ministry of Finance has published the Administrative Principles 2020. These replace the version of 2005 to some extent, but there is a greater emphasis on procedural aspects.

Our colleagues in Hungary explain the current focus of the Hungarian tax authority at Hungarian subsidiaries of foreign companies under the aspect of transfer pricing following the COVID-19 crisis.

In Italy, new rules came into force regarding the structure, content, and submission of the transfer pricing documentation. These changes apply to both the master file and the local file and have significant implications for the taxpayer.

For other countries, please see here