Global Transfer Pricing Newsletter #3/2021

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

In the latest edition of the WTS Global Transfer Pricing Newsletter, our colleagues from 15 countries provided an update on recently introduced Transfer Pricing legislations and cases, in particular the adoption of certain OECD Guidelines. Additionally, global developments like the Pillar 1 and Pillar 2 initiative, global minimum tax and new control mechanisms to ensure the correct taxation of corporate profits are presented.


Our Austrian colleagues summarize the changes in the final version of the Austrian Transfer Pricing Guidelines 2021 and highlight the most important aspects (see Newsletter issue #2.2021).

The Belgian contribution sheds light on a decision of the Court of Appeal of Ghent in favor of the taxpayer, which provides rare insights into the legal opinion on the application of the OECD Guidelines and other elements.

In France, our colleagues discuss the Engie SA case and highlight the ambitious new approach proposed by the French Tax Administration here.

In Germany, a new tax law as well as new administrative guidance governing transfer pricing aspects in the country have been published. In two articles, the “Withholding Tax Relief Modernization Act” and the “Administrative Principles Transfer Pricing” are presented and discussed in more detail.

In Ukraine, the State Tax Service is strengthening Transfer Pricing controls in three stages. The article provides more details and the impact on taxpayers.

Further Countries

In Argentina, the Argentine Revenue Service published a new document listing recommendations for Transfer Pricing in financial years, which are influenced by the COVID-19 crisis.

Our colleagues in Benin explain recent updates in local tax law that affect Transfer Pricing and outline the contents of the newly established Transfer Pricing declaration.

In Chile, the focal point of the local Tax Administration has recently shifted to specific fieldsof Transfer Pricing. Our colleagues from Chile elaborate on this.

In September 2021, the Tax Administration in China gave feedback on five practical questions on Transfer Pricing issues in connection with the COVID-19 pandemic. The article provides a brief overview on the proposed implications.

Our colleagues in Nigeria provide an update on a Transfer Pricing case of the local Tax Appeal Tribunal (see Newsletter issue #1.2021).

Senegal has adopted – among others – action 12 of the BEPS project in its tax system so as to automatically obtain information on financial accounts and the ownership of companies.

The Taiwanese Supreme Administrative Court decides on one-time Transfer Pricing adjustments. Our colleagues present the specifics concerning the development, the background and the decision of the court.

In Thailand, recently, major changes have been made in view of local Transfer Pricing disclosure regulations. The article gives a summary of the newly established focal points as well as practical insights.

The US contribution highlights the role of the United States within the ongoing changes in the global tax world due to the Pillar 1 and Pillar 2 deals.

In Vietnam, the Tax Administration has announced that it will pay particular attention to Transfer Pricing compliance issues, specifically to highlighting deficiencies in the identification of related party transactions.

If you have any questions regarding any aspects of this newsletter, our Global Transfer Pricing experts will be happy to answer them.

For the full Newsletter, please see WTS Global Transfer Pricing Newsletter #3/2021


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