NewsFlash April 2024

Upcoming Transfer Pricing Deadlines 

Argentina: May 31st  

    • 2nd Country-by-Country Report Notification, for companies whose ultimate parent entity submits the Country-by-Country Report in March 2024.   

Bolivia: May 31st (extension) 

    • F.601 – Informative Declaration. 
    • Local File.  

Mexico: May 15th  

  • Annex 9 of the DIM (declaración informativa múltiple). 
  • Transfer pricing annex of the tax return. 
  • Local File. 

Australia: Australian tax administration’s transfer pricing performance assessed  

On April 17, the Australian National Audit Office (ANAO) released an audit report to the Australian Taxation Office (ATO) on the ATO’s use of transfer pricing mechanisms in relation to Australian companies’ foreign related party debts.   

The purpose of the audit report was to provide assurance to Parliament that the ATO is managing its approach to foreign related party debts effectively, using sound strategies and processes, as this has been identified as a key risk due to the significant increase in interest expense incurred by Australia’s major companies with foreign affiliates.   

 You can read the full report here. 

Bolivia: deadlines for filing transfer pricing documentation extended  

The National Tax Service (SIN), through Regulatory Resolution (RND) No.102400000011, dated April 19th, 2024, extended until May 31st the deadline for filing transfer pricing documentation, among other tax documentation, for taxpayers whose fiscal year ends on December 31st, 2023.   

To consult the resolution, click here.  

Chile – Mexico: Chile publishes summarized text in Spanish of the treaty with Mexico as amended by the Multilateral Instrument (MLI) 

The Chilean internal revenue service recently published a summarized version in Spanish of the treaty to avoid double taxation and prevent tax evasion in income and wealth tax matters between Chile and Mexico (1998), showing the modifications made by the Multilateral Instrument (MLI). The document was prepared by the Chilean competent authority and represents its understanding of the modifications made to the treaty by the MLI.  

The purpose of the summarized text is to facilitate the understanding of the application of the MLI but does not in itself constitute a law.  

To consult the summary, click here. 

Cyprus: tax authority clarifies concerns on transfer pricing rules  

On March 28, 2024, the Cyprian tax department published on its website answers to frequently asked questions (FAQs) related to transfer pricing. These FAQs provide more detailed guidance on the transfer pricing documentation regulations implemented as of tax year 2022. The tax authority will continue to supplement these FAQs over time, and taxpayers are advised to watch this section for any additional clarifications that may be published in the future.   

The FAQs can be consulted here. 

Czech Republic: tax authorities increase transfer pricing audits  

According to a press release issued by the Czech tax authorities, in recent years the tax administration has increased transfer pricing audits, from 249 investigations in 2020 to 570 in 2023, resulting in an increase in the tax base and a reduction of tax losses.  

The audits have focused on reviewing the resale operations of advertising services and the licensing of the use of intangible assets. The tax authorities note that there has been an increase in cases where intangible assets, are transferred between related parties to shift profits out of the Czech Republic, selling these assets abroad at minimal price or even giving them for free, and then charging substantial licensing fees for their use to the original Czech owner.   

The full text of the press release can be found here.   

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