Transfer Pricing Updates

BRAZIL

• July 21, 2022: Brazilian Federal Revenue Service and the Inter-American Development Bank hold seminar as part of process to present new Brazilian transfer pricing system

CHINA

• June 28, 2022 – Customs and Tax Authorities in Shenzhen launch collaborative management of transfer pricing related to goods imported from related parties

CYPRUS

• July 1, 2022 – Cyprus introduces transfer pricing rules and documentation requirements (EY)
• July 28, 2022: Cyprus introduces TP documentation (PwC)
• August 9, 2022: Cyprus introduces new Transfer Pricing legislation (Coperitas)
• September 6, 2022: Cyprus Tax Authority issues notification with respect to newly introduced transfer pricing rules and documentation requirements (EY)

GUATEMALA

• August 25, 2022: Preliminary transfer pricing analysis prior to year end may benefit taxpayers (Deloitte)

HUNGARY

• July 22, 2022 – New Hungarian transfer pricing rules impose additional reporting requirements and require adjustments to the median
• August 8, 2022: Hungary’s 2023 Budget Law Published Including Transfer Pricing Changes from 2022

ISRAEL

• August 2, 2022: Israel’s Three-Tiered Transfer Pricing Documentation Requirements Apply from 2022

THE NETHERLANDS

• July 4, 2022 – The Netherlands issues new transfer pricing decree
• July 22, 2022 – Dutch Ministry of Finance publishes new transfer pricing decree

POLAND

• Spetember 2, 2022: Poland proposes changes to transfer pricing regulations

PORTUGAL

• Amendments to Transfer Pricing legislation (WTS)

SAUDI ARABIA

• August 3, 2022: Saudi Arabia to Extend Transfer Pricing Requirements to Zakat Payers (Orbitax)

UNITED KINGDOM

• July 25, 2022 – UK Government released draft legislation introducing new transfer pricing documentation requirements for ‘UK businesses’
• August 4, 2022: New transfer pricing documentation requirements enhance HMRC’s information gathering powers and taxpayers’ penalty risks (Baker & McKenzie)