Most recent changes in the law
The extended deadline for the submission of transfer pricing documentation – Regulation of the Minister of Finance of 14 March 2018
Following major changes to the regulatory environment, the first documentation of transactions with related parties executed in 2017 can be drafted by 30 September 2018 and not, as originally assumed, by 31 March 2018. According to the clarifications provided by the Ministry of Finance, tax payers obligated to draft documentation of transactions with related parties are obliged to specify whether or not they take advantage of the extended deadline for drafting said documentation in their annual tax return. The use of the extended deadline for drafting the documentation will not necessitate filing a corrected tax return.
The Ministry further explained that the seven-day deadline for filing the tax documentation at the request of the tax authority exclusively applies to documentation which has gone over the filing deadline. Therefore, if a tax payer elects to draft the documentation any day before the end of September 2018, the tax authorities will not be in a position to request that the tax payer files the 2017 documentation before that date.
Tax Decisions and Rulings
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Positive individual tax ruling will also protect VAT refund entitlement
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Actual impact on a company to be considered before granting exemption from a taxation of interest
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Accounting and IT services expenses, and some know-how fees to be charged against costs in full
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The threshold for documenting loans for transfer pricing purposes to be defined, not only by interest, but also by principal
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Planned changes to the legal environment
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Ratification of multilateral amendments to double-taxation treaties (MLI BEPS)
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Changes to the recently amended income tax acts
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