On April 27, 2021, the United Nations (UN) released the latest edition of its practical manual on transfer pricing for developing countries.
The manual improves existing guidance and introduces new elements in response to some of the cutting-edge issues in transfer pricing. The manual is focused on transfer pricing in a global environment, while it provides guidance on design principles and policy considerations.
The manual also addresses the practical implementation of a transfer pricing regime in developing countries and shares examples of country practices from developing countries, such as Brazil, China, India, Kenya, Mexico, and South Africa.
On April 23, 2021, the South African Revenue Service published interpretation notes on withholding tax on interest and royalties.
Interpretation Note 115, on withholding tax on interest, deals with the interpretation and application of sections 50A to 50H relating to withholding tax on interest.
Interpretation Note 116, on withholding tax on royalties, provides guidance on the interpretation and application of sections 49A to 49H which relate to withholding tax on royalties.
See Interpretation Notes
On April 15, 2021, the OECD released stage 2 peer review monitoring reports for eight countries as part of its work on BEPS Action 14.
The OECD has released reports for the following eight counties: Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand and Portugal.
The reports evaluate the progress made by these eight jurisdictions in implementing any recommendations resulting from their stage 1 peer review. They take into account any developments in the period January 2018-August 2019 and build on the MAP statistics for 2016-2018.
The OECD's Committee on Fiscal Affairs has designated Fabrizia Lapecorella, Director General of Finance of the Italian Ministry of Economy and Finance, as the next Chair of the Committee beginning on January 1, 2022.
Lapecorella will take over from Mr. Martin Kreienbaum of Germany after his 5-year term ends on December 31, 2021.
Lapecorella will be the second female Chair of the Committee since it was created in 1971 and the second Italian to hold this position.
On April 14, 2021, the US Treasury Department invited public recommendations on items to be included on the 2021-2022 Priority Guidance Plan.
The 2021-2022 Priority Guidance Plan will identify guidance projects that the Treasury Department and the Service intend to actively work on as priorities during the period from July 1, 2021, through June 30, 2022.
Recommendations must be received by May 28.
On April 7, 2021, Ireland’s Minister for Finance, Paschal Donohoe, launched a public consultation on the country’s Tax Treaty Policy.
The public and interested stakeholders are invited to give their views on the issues detailed in the public consultation document. Responses received on the policy issues detailed in this public consultation will form part of the consideration the tax treaty policy statement, which will set out the broad parameters of Ireland’s treaty policy.
The consultation period will run until May 7, 2021.
See Consultation document
On April 5, 2021, the Indian government notified the Income Tax (9th Amendment) Rules, 2021.
The Rules increase the country-by-country reporting threshold from INR 55 billion to INR 64 billion.
The Rules came into force on April 1, 2021.
On April 1, 2021, the OECD released the latest peer review report assessing jurisdictions' efforts to prevent tax treaty shopping and other forms of treaty abuse under Action 6 of the BEPS project.
The report reveals that a large majority of members of the Inclusive Framework on BEPS are translating their commitment on treaty shopping into actions and are modifying their treaty network.
The latest report includes the aggregate results of the peer review and data on tax treaties concluded by each of the 137 jurisdictions that were members of the Inclusive Framework on June 30, 2020. The data demonstrate that the BEPS Multilateral Instrument (MLI) has been the tool used by the vast majority of jurisdictions that have begun implementing the Action 6 minimum standard, and that the MLI has started to impact tax treaties of jurisdictions that have ratified it.