COVID-19 Response Tracker - Transfer Pricing - 16 July 2020
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COVID-19 Response Tracker — Transfer Pricing 16 July 2020
Important notes
• This document provides a snapshot of the transfer pricing related changes that have been announced in jurisdictions around the world
in response to the COVID-19 pandemic. It is designed to support conversations about changes that have been proposed or implemented
in key jurisdictions.
• These types of changes across the globe are being proposed and implemented on a daily basis. This document is updated on an ongoing
basis but not all entries will be up-to-date as the process moves forward. In addition, not all jurisdictions are reflected in this document.
• Find the most current version of this tracker on ey.com.
• Please consult with your EY engagement team to check for new developments and to understand the implication of ongoing changes.
EY teams have developed additional trackers to help you assess the follow changes:
► Force Majeure
► Global Mobility
► Global Tax Policy
► Global Trade Considerations
► Immigration Policy
► Labor and Employment Law
► Tax Controversy
► US State and Local Taxes
EY professionals are updating the trackers regularly as the situation continues to develop.
Questions or comments: globaltaxpolicyandcontroversy@ey.com
Page 2 COVID-19 Response Tracker - Transfer Pricing51 Jurisdictions covered
Argentina Finland Luxembourg Kingdom of Saudi Arabia
Australia France Malaysia Singapore
Austria Germany Mexico South Africa
Belgium Ghana The Netherlands South Korea
Brazil Greece New Zealand Sweden
Canada Hong Kong Nigeria Switzerland
Chile Hungary Norway Taiwan
China Mainland India Pakistan Uganda
Colombia Ireland Peru United Arab Emirates
Croatia Israel Philippines United Kingdom
Czech Republic Italy Portugal United States
Denmark Japan Romania Vietnam
Egypt Kenya Russia
Jurisdictions in bold font have been updated in this edition
Page 3 COVID-19 Response Tracker -
Jurisdictions in red font are new in this edition
Transfer PricingGlossary of terms
APA Advance Pricing Agreement MNE Multinational enterprise
CA Competent Authority MTC Markup on total costs
CbCR Country-by-Country Reporting OECD Organisation for Economic Cooperation and Development
CIT Corporate Income Tax SPE Surrogate Parent Entity
FYE Fiscal Year End TP Transfer pricing
LF Local File TPG Transfer Pricing Guidelines
MF Master File UPE Ultimate Parent Entity
Page 4 COVID-19 Response Tracker -
Transfer Pricing• Contact: Hernán Ubertazzi
Argentina • Contact: Milton Gonzalez
• Last updated: 13 June 2020
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing obligation Applicable deadlines per local regulations usually New submission deadlines per COVID-19- Related comments
type in force specific measures (if any)
Transfer pricing ► The deadline is six months after the fiscal ► TP reporting obligations were suspended ► Transfer pricing documentation includes: Local file, CPA certification,
documentation year-end (TP Report and TP form). In cases of before COVID-19 due to a major tax Master File and Form F2668.
Masterfile submission, the deadline is 12 reform program that included updating
► The new rules focus on further details about the following inter-
months after the fiscal year-end. of TP documentation requirements. As of
company transactions/analysis to be included in the TP Report:
Contemporaneous today, the Tax Authorities has granted a
requirements: No ► For FYE December 2018 – May 2019, the
one-month extension for FYE December ► International Intermediary (import and export of goods)
deadline is 10-14 July 2020.
2018-May 2019 year-ends, from a 10-14
June to a 10-14 July 2020 deadline. ► Financial loans, cash-pools, etc.
► For FYE June 2019 – November 2019, the
deadline is 10-14 August 2020. ► Services received (benefit test)
► It is not expected that Tax Authority will
► For FYE December 2019 – April 2020, the grant any further extensions. ► Intangible assets
deadline is 10-14 October 2020.
► Business restructurings
► Segmentation of financial information
► Further information regarding the MNE group
Transfer Pricing The Transfer Pricing form that business should fill As above New form F2668 replaces the previously used forms. Further
declaration/form/filing out is F2668. However the correct web page implementation rules are yet to be published regarding this form, as it is
where it should be filled out is still not available in not yet available in the Tax Authorities webpage.
the Tax Authority's website, Further details are
Contemporaneous expected later in June, 2020.
requirements: No
CbCR notification First Notification: Last business day of third No It is required for all local entities that belong to a MNE group
month after FYE of Ultimate Parent Entity (UPE).
Second Notification: Last business day of the
Contemporaneous
requirements: No second month after due date of the Country by
country report (CbCR) in the applicable
jurisdiction.
Page 5 COVID-19 Response Tracker - Transfer PricingArgentina (continued)
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Transfer Pricing obligation Applicable deadlines per local regulations New submission deadlines per COVID-19- Related comments
type usually in force specific measures (if any)
CbC report CbCR is due within 12 months of the FYE. No The filing of a CbCR report is required for local UPE of MNE, in cases
where the local entity is designated as the reporting entity, and in cases
where the jurisdiction where the CbCR is submitted does not have an
Contemporaneous exchange information agreement with Argentina regarding CbCR.
requirements: No
Are there any COVID-19-related impacts on transfer pricing-specific audits? N/A
Link to EY Tax Controversy Response Tracker for further audit-specific information Link
Have there been any impacts or changes to Advanced Pricing Agreements (APAs), Rulings, or other transfer pricing related No
certainty measures?
Implementation of transfer pricing-specific stimulus measures, e.g., safe harbors? No
EY and Government resources, links, publications, etc.
Link to the EY Worldwide Transfer Pricing Reference Guide Link
Page 6 COVID-19 Response Tracker - Transfer Pricing• Contact: Peter Austin
Australia • Contact: Anthony Seve
• Last updated: 18 May 2020
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing obligation type Applicable deadlines per local New submission deadlines per COVID- Related comments
regulations usually in force 19-specific measures (if any)
Transfer pricing documentation ► Income tax return is generally due No changes to submission deadlines as a ► Transfer pricing documentation is required to be prepared (but not submitted) by the due
six months and 15 days after result of COVID-19. date of the income tax return.
financial year end.
► Australian Local File is a separate obligation to the transfer pricing documentation which is
Contemporaneous requirements:
Yes ► Australian Local File and group required to be prepared and lodged with the Australian Tax Office (ATO).
Master File required to be
► Group Master File prepared in accordance with OECD requirements required to be lodged
submitted within 12 months of
as an attachment to the Australian Local File.
financial year end.
► Failure to prepare contemporaneous transfer pricing documentation has implications for
► Australian Local File Part A may
penalty protection.
be submitted with the income tax
return in lieu of completing ► Significant penalties associated with failure to submit Australian Local File and Master File
Questions 2 through 17 of the (up to a maximum of A$525,000 per lodgement).
International Dealings Schedule
(IDS).
Transfer Pricing As above. No changes to submission deadlines as a ► Part A of the Australian Local file may be lodged in lieu of completing questions 2 through
declaration/form/filing result of COVID-19. 17 of the IDS (if Country-by-Country Reporting applies to the entity).
► IDS required to be completed and lodged with the income tax return.
Contemporaneous requirements:
No
CbCR notification 12 months after financial year end. No changes to submission deadlines as a Only relevant if CbCR is lodged in jurisdiction exchanging with Australia. Otherwise lodgement
result of COVID-19. of CbCR in Australia will be required.
Contemporaneous requirements:
No
Page 7 COVID-19 Response Tracker - Transfer PricingAustralia (continued)
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Transfer Pricing Applicable New submission deadlines Related comments Are there any COVID-19- N/A
obligation type deadlines per per COVID-19-specific related impacts on
local measures (if any) transfer pricing-specific
regulations audits?
usually in force
CbC report 12 months No changes to submission Local submission only required if not lodged in a Link to EY Tax Link
Controversy Response
after financial deadlines as a result of jurisdiction exchanging with Australia. Tracker for further
year end. COVID-19. audit-specific
Significant penalties associated with failure to submit
Contemporaneous information
requirements: No CbCR if required (up to a maximum of A$525,000 per
lodgement).
Have there been any No specific changes.
impacts or changes to
APAs, rulings, or other
transfer pricing related
certainty measures?
Implementation of No transfer pricing specific stimulus measures.
transfer pricing-specific
stimulus measures, e.g.,
safe harbors?
EY and Government
resources, links,
publications, etc.
Link to the EY Worldwide Link
Transfer Pricing
Reference Guide
Page 8 COVID-19 Response Tracker - Transfer Pricing• Contact: Gerhard Steiner • Contact: Kathrin Schmit
Austria • Contact: Manuel Taferner
• Contact: Andreas Stefaner
• Last updated: 13 May 2020
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing Applicable deadlines per local regulations New submission Related comments Are there any COVID- N/A
obligation type usually in force deadlines per COVID- 19-related impacts on
19-specific transfer pricing-
measures (if any) specific audits?
Transfer pricing According to the Transfer Pricing No TP documentation is highly Link to EY Tax Link
documentation Documentation Law, TP documentation recommended to be ready when the tax Controversy
must be submitted upon request of the return for the respective year is filed. TP Response Tracker for
competent tax office within 30 days after documentation is usually requested / further audit-specific
Contemporaneous the constituent entity files its tax return provided in the course of tax audits. information
requirements: No According to a published opinion of the
Austrian Ministry of Finance, transfer Have there been any No
pricing documentation should be available impacts or changes to
when the tax returns are filed. APAs, rulings, or
other transfer pricing
related certainty
Transfer Pricing N/A N/A Transfer Pricing declaration/form/filing measures?
declaration/form/ obligations are not applicable in Austria.
filing
Implementation of No
Contemporaneous
transfer pricing-
requirements: N/A
specific stimulus
measures, e.g., safe
CbCR notification CbCR notification must be filed to the No CbCR notification needs to be filed by harbors?
respective tax office by the end of the each constituent entity on a yearly basis.
fiscal year for which CbCR will be filed.
Contemporaneous EY and Government
requirements: No resources, links,
publications, etc.
CbC report CbCR is due within 12 months following No N/A
the respective fiscal year end. Link to the EY Link
Worldwide Transfer
Contemporaneous Pricing Reference
requirements: No Guide
Page 9 COVID-19 Response Tracker - Transfer Pricing• Contact: Pierre Legros • Last updated: 11 May 2020
Belgium • Contact: Valentina Katunina
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing obligation Applicable deadlines per local regulations usually in force New submission deadlines per Related comments
type COVID-19-specific measures (if
any)
Transfer pricing TP documentation is required to be submitted upon request of the No N/A
documentation Belgian Tax Authorities in context of a TP audit. The deadline to
submit the TP documentation is 30 days as of the request.
Contemporaneous
requirements: No
Transfer Pricing The Local File TP Form (275.LF Form) is due at the same time as the For 275.LF Forms that were due in The Belgian mandatory TP Forms (Local File TP Form (275.LF
declaration/form/filing Corporate Income Tax return of the Belgian company/branch (given the period between 15 March and Form) and Master File Form (275. MF Form)) must be submitted to
that the 275.LF Form is an official appendix to the Corporate Income 30 April 2020, the deadline was the Belgian Tax Authorities if based on the financials of the
Tax Return). For a company with a calendar year-end, the Corporate extended until 30 April 2020. previous financial year, the Belgian company/branch meets or
Contemporaneous Income Tax return is typically due end of September of the year exceeds one or more of the following criteria:
requirements: No following the financial year-end.
► Operating and financial revenues (non-recurrent) of more than
The Master File Form (275.MF Form) is due within 12 months after EUR 50 million;
the end of the financial year of the Group to which it relates.
► Total assets of more than EUR 1 billion; or
► 100 Full Time Equivalents ('FTEs") in average.
Page 10 COVID-19 Response Tracker - Transfer PricingBelgium (continued)
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Transfer Pricing Applicable deadlines per New submission Related comments Are there any COVID-19- Pending tax audits are continuing. Pre-audit and other
obligation type local regulations usually deadlines per COVID- related impacts on meetings can be held by video/conference calls given
in force 19-specific measures transfer pricing-specific the lockdown in Belgium, and the Belgian Tax
(if any) audits? Authorities have also indicated that they are willing to
grant extensions of the 30-day deadline for responding
to TP audit questionnaires given the current
circumstances due to the COVID-19 pandemic.
The CbCR Notification No The CbCR Notification Form (275.CBC.NOT)
CbCR notification
Form (275.CBC.NOT has to be submitted by the Belgian
Form) is due at the latest company/branch in case the Group had a
Contemporaneous on the last day of the turnover equal to or more than EUR 750
Link to EY Tax Link
requirements: No reporting period of the million in the previous financial year. For Controversy Response
multinational group. reporting periods ending as from 31 Tracker for further audit-
December 2019 and beyond, the CbCR specific information
Notification Form has to be submitted
solely in those cases where the information Have there been any No
provided, differs from the information that impacts or changes to
was provided in the CbCR Notification Form APAs, rulings, or other
of the previous reporting period. transfer pricing related
certainty measures?
Implementation of No
No transfer pricing-specific
CbC report CbCR form (275.CBC) is CbCR applies to multinational groups with a stimulus measures, e.g.,
required to be submitted consolidated revenue equal to or exceeding safe harbors?
within 12 months after EUR 750 million. Belgian entities which are
Contemporaneous the end of group’s the ultimate parent or the surrogate parent
requirements: No financial year. entities of such multinational groups should EY and Government
annually file the 275.CBC form with Belgian resources, links,
Tax Authorities. publications, etc.
Link to the EY Worldwide Link
Transfer Pricing
Reference Guide
Page 11 COVID-19 Response Tracker - Transfer Pricing• Contact: Marcio R Oliveira
Brazil • Contact: Victor Nunes
• Last updated: 21 May 2020
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing Applicable deadlines per New submission deadlines Related comments Are there any COVID- Not applicable
obligation type local regulations usually in per COVID-19-specific 19-related impacts on
force measures (if any) transfer pricing-
specific audits?
Transfer pricing Transfer pricing There has been no The filing deadline for the Digital Accounting Link to EY Tax Link
documentation documentation needs to be communication on Bookkeeping (ECD), the basis for filling the tax Controversy
prepared up to the deadline postponement of deadlines return, has been postponed from 31 May to 31 Response Tracker for
of the tax return (usually due for the return. July 2020. A similar measure for the income tax further audit-specific
Contemporaneous by 31 July). return is expected. information
requirements: No
Have there been any Not applicable
impacts or changes to
APAs, rulings, or
other transfer pricing
related certainty
Transfer Pricing Same comments as above. Same comments as above Same comments as above measures?
declaration/form/
filing
Contemporaneous Implementation of Not applicable
requirements: No transfer pricing-
specific stimulus
measures, e.g., safe
CbCR notification Notification should be Same comments as above Notification is required whenever the Brazilian harbors?
provided in a specific block taxpayer is not the one entitled to file the CbC
of the income tax return Report.
Contemporaneous (usually due by 31 July). EY and Government Not applicable
requirements: No resources, links,
publications, etc.
CbC report CbCR should be filed as one Same comments as above The reporting threshold is annual group revenue
of the blocks of the income in the previous year of BRL 2.26 billion or more
Link to the EY Link
tax return (usually due by 31 (or EUR 750 million or equivalent in local
Worldwide Transfer
Contemporaneous July). currency). As a rule, the obligation to file a CbCR Pricing Reference
requirements: No applies for the ultimate parent company, although Guide
a local non-parent entity may be required to file as
long as some requirements are met.
Page 12 COVID-19 Response Tracker - Transfer Pricing• Contact: Rebecca Coke • Last updated: 26 May 2020
Canada • Contact: Paul Mulvihill
• Contact: Rene Fleming
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing obligation Applicable deadlines per local regulations usually New submission deadlines per COVID-19-specific measures (if Related comments
type in force any)
Transfer pricing ► Taxpayers are required to contemporaneously ► Submission deadlines for providing documentation are Transfer pricing documentation is only submitted if
documentation prepare transfer pricing documentation. If unchanged (three months), but administratively, on 31 March the CRA formally requests it in an information
requested to produce by Canada Revenue 2020 CRA announced that requests issued before 1 April 2020 request.
Agency (CRA), the taxpayer has three months and having submission deadlines of 18 March 2020 or later will
to submit. be considered cancelled and will be re-issued at a later date.
Contemporaneous This is in order to provide taxpayers with the full three months
requirements: Yes ► Corporate income tax return (due six months
after fiscal year end for corporations and five allowed.
months for partnerships) simply ask the ► On 25 May 2020 the CRA announced an extension of time to
question as to whether the taxpayer has file corporate tax returns to 1 September 2020 for returns due
prepared or obtained contemporaneous in June, July or August 2020. Documentation is required to be
documentation as described in the Income Tax prepared by the date that the corporate tax return is due.
Act.
Transfer Pricing Taxpayers are required to file a T106 Information
declaration/form/filing Return reporting related-party transactions, on
the same timeline as for their corporate income
tax returns (see above).
Contemporaneous
requirements: No
CbCR notification N/A – No notification requirement in Canada N/A
Contemporaneous
requirements: N/A
CbC report Remains unchanged. CbCR is due 12 months after Returns due in June, July and August 2020 extended to 1
year-end September 2020
Contemporaneous
requirements: No
Page 13 COVID-19 Response Tracker - Transfer PricingCanada (continued)
Find the most current version of this tracker on ey.com Return to jurisdiction list
Are there any COVID-19-related impacts on transfer pricing- After initially suspending audit activity, CRA is slowly returning to audit activities; Field staff have significant
specific audits? IT/communications limitations; Focus is on cases facing imminent statutory or treaty-imposed deadlines for
reassessment.
Link to EY Tax Controversy Response Tracker for further Link
audit-specific information
Have there been any impacts or changes to Advanced Pricing APAs and MAPs have been designated as "critical services" for CRA; Competent Authority staff will resume work on
Agreements (APAs), Rulings, or other transfer pricing related APA and MAP cases but are subject to some IT / communications limitations.
certainty measures? https://www.canada.ca/en/revenue-agency/services/covid-19-employee-supplier/business-continuity-
plan.html?utm_source=Canada_dot_ca&utm_medium=News_Item&utm_campaign=CO_DCO+HRB+COVID19&utm_con
tent=2020-03-30_1297
Implementation of transfer pricing-specific stimulus N/A
measures, e.g., safe harbors?
EY and Government resources, links, publications, etc. https://www.canada.ca/en/revenue-agency/services/covid-19-employee-supplier/business-continuity-
plan.html?utm_source=Canada_dot_ca&utm_medium=News_Item&utm_campaign=CO_DCO+HRB+COVID19&utm_con
tent=2020-03-30_1297
https://www.canada.ca/en/revenue-agency/news/newsroom/tax-tips/tax-tips-2020/extended-filing-deadlines-
corporations-trusts.html
Link to the EY Worldwide Transfer Pricing Reference Guide Link
Page 14 COVID-19 Response Tracker - Transfer Pricing• Contact: Ayleen Maturana Ferrés • Last updated: 22 May 2020
Chile • Contact: Janice Stein Vidal
• Contact: Jorge Angarita Gomez
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing Applicable deadlines per New submission deadlines Related comments Are there any COVID- N/A
obligation type local regulations usually in per COVID-19-specific 19-related impacts on
force measures (if any) transfer pricing-specific
audits?
Transfer pricing There is no specific No change Transfer pricing
documentation deadlines for the TP documentation should
documentation. only be available in case
of a TP audit.
Contemporaneous
requirements: Yes TP audits are very Link to EY Tax Link
common. Controversy Response
Tracker for further
audit-specific
Transfer Pricing In Chile there is an No change Every year, taxpayers information
declaration/form/ obligation to file an annual have the right to require
filing TP form (DJ 1907) that the extension of this Have there been any No COVID-19-specific measures. Chile has recently changed their
must be submitted before 1 deadline for maximum 90 impacts or changes to position about APA, being now a more common practice for
July 2020. additional days. APAs, rulings, or other taxpayers that the tax administration wants to apply for more
Contemporaneous transfer pricing related cases.
requirements: No certainty measures?
CbCR notification Included into Form 1907. No change Implementation of No specific stimulus related with transfer pricing.
There is an additional transfer pricing-specific
stimulus measures,
Contemporaneous notification only applicable e.g., safe harbors?
requirements: No in those cases where
surrogate entity in Chile is
designated by the Group. EY and Government
resources, links,
CbC report CBCR (Form 1937) must be No change Every year, taxpayers publications, etc.
submitted before 1 July, have the right to require
2020. the extension of this Link to the EY Link
Contemporaneous Worldwide Transfer
deadline for maximum 90
requirements: No Pricing Reference
additional days.
Guide
Page 15 COVID-19 Response Tracker - Transfer Pricing• Contact: Julian Hong
China Mainland • Contact: Kelly Y Chen
• Last updated: 16 May 2020
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing Applicable deadlines per local New submission deadlines per Related comments Are there any COVID- Not applicable
obligation type regulations usually in force COVID-19-specific measures (if 19-related impacts on
any) transfer pricing-
specific audits?
Transfer pricing Local file should be ready by 30 No Transfer pricing compliance Link to EY Tax Link
documentation June of the following year and obligation type and timeline does Controversy Response
should be submitted to tax not change in view of the COVID- Tracker for further
authorities within 30 days upon 19 pandemic. audit-specific
request. information
Contemporaneous
requirements: Yes Master file should be ready within Have there been any No
12 months following the fiscal impacts or changes to
year end of the group’s ultimate APAs, rulings, or other
holding company. transfer pricing
related certainty
Transfer Pricing measures?
Local transfer pricing declaration No
declaration/form/filing forms are due when filing
corporate income tax return: 31 Implementation of No
Contemporaneous May. transfer pricing-
requirements: No specific stimulus
measures, e.g., safe
harbors?
CbCR notification Not applicable No
Contemporaneous EY and Government
requirements: N.A. resources, links,
publications, etc.
CbC report Filing with corporate income tax No
return: 31 May.
Link to the EY Link
Worldwide Transfer
Contemporaneous Pricing Reference
requirements: No Guide
Page 16 COVID-19 Response Tracker - Transfer Pricing• Contact: Andres Parra • Last updated: 21 May 2020
Colombia • Contact: Monica Piedrahita
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing obligation type Applicable deadlines per local New submission deadlines per COVID- Related comments
regulations usually in force 19-specific measures (if any)
Transfer pricing documentation July every fiscal year for Local File. N/A Mandatory filing.
December every fiscal year for the
Masterfile. If intercompany transactions surpass USD 462.000 approx. per type of transaction, tax-payer
must file a local file for each of those transactions.
Contemporaneous requirements:
No Tax-payers subject to file the local file, must submit also the master file for FY 2019. This file could
be presented in English. Possibly there will be a modification in the deadline to submit said report
for fiscal year 2019 with respect to the previous year.
Transfer Pricing July every fiscal year. N/A Mandatory filing.
declaration/form/filing
Taxpayers whose gross equity is equal to or greater than US 1.025.000 approx. or whose
gross revenues are equal to or greater than USD 625.000 approx. would be liable to comply
with a transfer pricing return. This form includes the information from the related parties,
Contemporaneous requirements:
No amounts of the intercompany transactions, method applied, results obtained, among others.
CbCR notification July every fiscal year. N/A It should be noted that all Colombian taxpayers that belong to a MNE group must comply with
the CbC notification requirement even if they have no formal transfer pricing obligations. The
notification is embedded in the TP return if the Company is required to file TP return,
Contemporaneous requirements: otherwise, this obligation must be filed via email.
No
Page 17 COVID-19 Response Tracker - Transfer PricingColombia (continued)
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing Applicable New submission deadlines Related comments Are there any COVID-19- Yes. Suspension of the terms in the processes and
obligation type deadlines per per COVID-19-specific related impacts on administrative actions in tax, customs and exchange
local measures (if any) transfer pricing-specific matters in the national territory between 19 March
regulations audits? and 3 April 2020.
usually in force
CbC report December of N/A Mandatory filing. Link to EY Tax Link
each fiscal Controversy Response
Applies to taxpayers that are the controlling entity for Tracker for further
year.
the multinational group or that have been designated to audit-specific
Contemporaneous
requirements: No fulfil that role. Additionally, among other requisites, the information
entity must have reported consolidated revenue equal to
approx. US $895.000.000. Have there been any No
impacts or changes to
APAs, rulings, or other
transfer pricing related
certainty measures?
Implementation of No
transfer pricing-specific
stimulus measures, e.g.,
safe harbors?
EY and Government Resolution No. 000022 of 18 March 2020
resources, links,
publications, etc.
Link to the EY Worldwide Link
Transfer Pricing
Reference Guide
Page 18 COVID-19 Response Tracker - Transfer Pricing• Contact: Masa Saric
Croatia • Contact: Tamara Korkutovic
• Last updated: 19 May 2020
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing Applicable deadlines per New submission deadlines per COVID- Related comments Are there any No
obligation type local regulations usually 19-specific measures (if any) COVID-19-related
in force impacts on transfer
pricing-specific
audits?
Transfer pricing TP documentation should ► Due to changes in the Croatian Taxpayers are expected to prepare
documentation be prepared and available legislation (in force as of 8 April TP documentation (local file) to
upon Tax Authorities' 2020), the deadline for submission of prove the arm's length nature of the Have there been No
request. In practice the CIT returns is extended to six months transactions. The Croatian any impacts or
Contemporaneous tax authorities tend to instead of 4 months after financial legislation prescribes mandatory changes to APAs,
requirements: No. request that TP year ends (i.e., from 30 April 2020 to elements and generally follows the rulings, or other
documentation is 30 June 2020). OECD Guidelines. transfer pricing
submitted together with ► The respective amendment does not related certainty
CIT return which is due 4 apply to taxpayers whose financial measures?
months after financial year is different than calendar year
year end. (i.e., in case of bankruptcy, status Implementation of No
changes, termination of business). transfer pricing-
specific stimulus
Transfer Pricing PD-IPO form should be Together with the CIT return (i.e., on 30 Information on the receivables and measures, e.g., safe
declaration/form/filing submitted together with June 2020). Respective change does not liabilities in transactions with harbors?
CIT return (i.e. 4 months apply to taxpayers whose financial year is related entities should be submitted
after financial year ends). different than calendar year. in the PD-IPO form.
Contemporaneous
requirements: No EY and Government https://narodne-
resources, links, novine.nn.hr/clanci/sluzbeni/2020_04_43_
publications, etc. 895.html
CbCR notification CbCR notification should Together with CIT return (i.e., on 30 Taxpayers should prepare CbCR
be submitted together June 2020). Respective change does not Notification to the Tax Authorities
with CIT return (i.e., 4 apply to taxpayers whose financial year is informing them of the identity, tax
Contemporaneous months after financial different than calendar year. residence and the jurisdiction of the Link to the EY Link
requirements: No year ends). ultimate parent entity or surrogate Worldwide Transfer
parent entity/constituent entity Pricing Reference
which would submit the CbCR in its Guide
jurisdiction of residence.
CbC report CbC report should be N/A Subject to this report are Croatian
submitted no later than 12 residents ultimate parent entities
months after the last day with consolidated revenue equal to
Contemporaneous of the reporting fiscal or more than EUR 750m (app. HRK
requirements: No year. 5.7 billion).
Page 19 COVID-19 Response Tracker - Transfer Pricing• Contact: Libor Fryzek
Czech Republic • Contact: Lucie Karpiskova
• Last updated: 18 May 2020
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing Applicable deadlines per New submission deadlines per COVID- Related comments Are there any N/A
obligation type local regulations usually in 19-specific measures (if any) COVID-19-related
force impacts on transfer
pricing-specific
audits?
Transfer pricing Local file is due upon N/A TP documentation is not
documentation request from the tax obligatory in the Czech Republic. Link to EY Tax Link
authority. Rather, it is highly Controversy
recommended. However, it must Response Tracker
Contemporaneous be submitted to the tax for further audit-
requirements: No authorities upon request. specific information
Have there been any No
impacts or changes
to APAs, rulings, or
other transfer
Transfer Pricing Transfer Pricing appendix N/A pricing related
declaration/form/filing must be filed with certainty measures?
corporate income tax
return which is due three
Contemporaneous months after year-end or Implementation of No
requirements: No six months after year-end. transfer pricing-
specific stimulus
measures, e.g., safe
CbCR notification CbCR notification is due at N/A harbors?
year-end.
Contemporaneous
EY and Government N/A
requirements: No
resources, links,
publications, etc.
CbC report CbC report is due 12 N/A
months after year-end.
Link to the EY Link
Contemporaneous Worldwide Transfer
requirements: No Pricing Reference
Guide
Page 20 COVID-19 Response Tracker - Transfer Pricing• Contact: Henrik Arhnung
Denmark • Last updated: 22 May 2020
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing Applicable deadlines per local New submission deadlines Related comments Are there any COVID- No, but in March 2020 the Danish tax
obligation type regulations usually in force per COVID-19-specific 19-related impacts on authorities indicated that they would
measures (if any) transfer pricing-specific primarily focus on issuing proposed
audits? assessments related to already ongoing TP
audits where the income year 2014 became
Transfer pricing Contemporaneous TP N/A TP documentation to be submitted time barred on 1 May 2020 and therefore
documentation documentation is required to be upon request in context of a tax audit. would not initiate any new TP audits until 1
prepared, and must be May 2020. However, we have now
A TP declaration, which is part of the experienced that the Danish tax authorities
Contemporaneous submitted, with 60 days notice, tax return, must be submitted annually.
requirements: Yes upon request from the tax have initiated a number of new TP audits
authorities. The Government has issued a bill toward the end of April and at the beginning
proposing that the Master file and local of May 2020, wherein they have requested
file should be submitted no later than companies to submit TP documentation
60 days after the tax return has been within 60 days.
submitted. If enacted, it will apply as of
financial income years starting on Link to EY Tax Link
1 January 2020 onward. Controversy Response
Tracker for further
audit-specific
Transfer Pricing The TP Declaration, filed as part Postponed for 2 months. information
declaration/form/filing of the tax return, should be Companies with calendar
submitted six months after year should normally file Have there been any No
Contemporaneous submission of corporate income the TP declaration on 1 impacts or changes to
requirements: No tax return. July but it has been APAs, rulings, or other
postponed until 1 transfer pricing related
September 2020 certainty measures?
CbCR notification No later than financial year-end. N/A
Implementation of No
Contemporaneous transfer pricing-specific
requirements: No stimulus measures,
e.g., safe harbors?
CbC report 12 months after year-end. N/A EY and Government N/A
resources, links,
Contemporaneous publications, etc.
requirements: No
Link to the EY Link
Worldwide Transfer
Pricing Reference Guide
Page 21 COVID-19 Response Tracker - Transfer Pricing• Contact: Ahmed El Sayed • Last updated: 21 May 2020
Egypt • Contact: Mohamed M Ahmed
• Contact: Samarth O Sharma
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Transfer Pricing Applicable deadlines per local New submission deadlines per Related comments Are there any COVID- We have not been aware of any specific
obligation type regulations usually in force COVID-19-specific measures 19-related impacts on impacts. However, pending TP audits are
(if any) transfer pricing- continuing but the Egyptian Tax Authority is
specific audits? likely more flexible due to current
circumstances.
Transfer pricing Two months after the N/A TP documentation is obligatory to be
documentation submission of the corporate tax submitted annually starting from
return. FY2018.
Have there been any APAs have not yet been implemented by the
Contemporaneous impacts or changes to Egyptian Tax Authority
requirements: Yes APAs, rulings, or
other transfer pricing
related certainty
measures?
Implementation of No
Transfer Pricing N/A N/A N/A transfer pricing-
declaration/form/filing specific stimulus
measures, e.g., safe
Contemporaneous harbors?
requirements: N/A
EY and Government
CbCR notification All notifications must be made N/A N/A resources, links,
no later than the last day of the publications, etc.
Contemporaneous fiscal year to which the CbCR
requirements: No relates.
Link to the EY Link
Worldwide Transfer
Pricing Reference
CbC report CbCR must be filed with ETA no N/A N/A Guide
later than 12 months after the
Contemporaneous last day of the fiscal year to
requirements: No which the CbCR relates.
Page 22 COVID-19 Response Tracker - Transfer Pricing• Contact: Kennet Pettersson • Last updated: 22 May 2020
Finland • Contact: Mikael Turunen
• Contact: Juhani Pietarinen
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Transfer Pricing Applicable deadlines New submission deadlines per COVID-19- Related comments Are there any COVID- No (none published yet).
obligation type per local regulations specific measures (if any) 19-related impacts on
usually in force transfer pricing-
specific audits?
Transfer pricing There is no statutory N/A Link to EY Tax Link
documentation deadline for submission Controversy
of transfer pricing Response Tracker for
Contemporaneous documentation. The further audit-specific
requirements: No taxpayer shall submit information
TP documentation
within 60 days upon
request, however not Have there been any No (none published yet).
earlier than six months impacts or changes to
after year-end. APAs, rulings, or
other transfer pricing
related certainty
Transfer Pricing Form 78: CITR deadline CITR deadline automatically extended by measures?
declaration/form/filing (4 months after year one month for fiscal years ending between
end, application for December 2019 – February 2020.
extension available e.g. Implementation of No (none published yet).
Contemporaneous transfer pricing-
requirements: No due to illness).
specific stimulus
measures, e.g., safe
CbCR notification CbCR notification is due N/A harbors?
on the last day of
Contemporaneous ultimate parent entity's EY and Government https://www.vero.fi/en/About-
requirements: No fiscal year. resources, links, us/newsroom/news/uutiset/2020/filing-
publications, etc. deadline-for-corporate-tax-returns-extended-
by-one-month/
CbC report The CbC report is due N/A
within 12 months
Contemporaneous following fiscal year Link to the EY Link
end. Worldwide Transfer
requirements: No
Pricing Reference
Guide
Page 23 COVID-19 Response Tracker - Transfer Pricing• Contact: Emmanuelle Leroy
France • Contact: Frank Deleon
• Last updated: 9 June 2020
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Transfer Pricing Applicable deadlines per local New submission deadlines per COVID-19-specific Related Are there any No specific developments noted in relation to
obligation type regulations usually in force measures (if any) comments COVID-19-related TP audits, but in practice tax audits have been
impacts on transfer frozen in many cases and will only relaunch in
pricing-specific June. Further, no new tax audit are expected
audits? until July 2020.
Transfer pricing TP documentation (local file and No Any pending TP
documentation mastefile) is due within 30 days documentation
upon request from the tax requests were Link to EY Tax Link
administration in the context of tax postponed, so the Controversy
Contemporaneous audit. 30 days deadline Response Tracker
requirements: No for submission is for further audit-
extended until specific information
the end of the
State of Sanitary Have there been any No – work of Competent Authority (CA)
Emergency. impacts or changes slowed down and postponement of several
to APAs, rulings, or bilateral meetings with counterparty CAs.
other transfer
pricing related
Transfer Pricing Transfer Pricing appendix must be The TP declaration for FYE 31 December 2019 certainty measures?
declaration/form/fili filed within six months from may be submitted up to 31 December 2020 (i.e.,
ng deadline for filing of corporate six months after the revised deadline for filing the
income tax return which is due CIT return (see below)). For companies with fiscal Implementation of No
three months after year-end year-ends other than 31 December that benefit transfer pricing-
Contemporaneous (except for 31 December year-end, from a deferred date for filing their CIT return, specific stimulus
requirements: No the deadline is four months later). deferred filing of the TP declaration is also measures, e.g., safe
permitted. Additional details have not been harbors?
provided at this stage by the French Tax Authority.
CbCR notification Notification is due with the CIT Yes – for CIT returns due from 31 December 2019
return. to 29 February 2020, the filing date has been EY and Government https://www.impots.gouv.fr/portail/node/13
postponed to 30 June 2020. For returns due from resources, links, 467
Contemporaneous 1 March to 31 March 2020, the filing date has publications, etc.
requirements: No been postponed to 31 July 2020.
Link to the EY Link
CbC report Filing is due 12 months after year- No Worldwide Transfer
end. Pricing Reference
Guide
Contemporaneous
requirements: No
Page 24 COVID-19 Response Tracker - Transfer Pricing• Contact: Laura Ordemann
Germany • Oliver Wehnert
• Last updated: 22 May 2020
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Transfer Pricing Applicable deadlines per local regulations usually in New submission Related comments Are there any COVID- To some extent.
obligation type force deadlines per 19-related impacts on Some tax audits continue (some with delay),
COVID-19-specific transfer pricing- some are postponed (always depending on the
measures (if any) specific audits? individual tax auditor), but no official statement
in this regard so far.
Transfer pricing According to German transfer pricing documentation N/A
documentation rules, tax auditors have the right to request transfer
pricing documentation for transactions between a
German taxpayer and his foreign-related parties, and Link to EY Tax Link
Contemporaneous the taxpayers have to submit the documentation Controversy
requirements: Yes within 60 days upon request (extraordinary business Response Tracker for
transactions within 30 days upon request; transfer further audit-specific
pricing documentation has to be prepared six months information
after end of the fiscal year).
Have there been any N/A
impacts or changes to
APAs, rulings, or
other transfer pricing
Transfer Pricing No specific disclosure requirements, however, relevant N/A related certainty
declaration/form/filing tax return forms may include certain questions. measures?
Contemporaneous Implementation of N/A
requirements: No transfer pricing-
specific stimulus
measures, e.g., safe
CbCR notification The CbCR notification has to be filed with the tax N/A harbors?
return for the relevant fiscal year.
Contemporaneous EY and Government Link
requirements: No resources, links,
publications, etc.
CbC report The deadline for filing the CbCR is one year after the N/A
end of the relevant fiscal year.
Contemporaneous
requirements: No
Page 25 COVID-19 Response Tracker - Transfer Pricing• Contact: Isaac N Sarpong
Ghana • Contact: Kofi A Akuoko
• Last updated: 19 May 2020
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Transfer Pricing Applicable deadlines New submission deadlines per Related Are there any COVID-19-related impacts on Field audits have noticeably
obligation type per local regulations COVID-19-specific measures (if any) comments transfer pricing-specific audits? slowed down, although they
usually in force are ongoing.
Transfer pricing TP documentation No
documentation submitted upon
request in context of
tax audit. Have there been any impacts or changes to No
Contemporaneous APAs, rulings, or other transfer pricing
requirements: Yes related certainty measures?
Implementation of transfer pricing-specific No
stimulus measures, e.g., safe harbors?
Transfer Pricing TP Return: within Two month extension for a total of six months TP Return is
declaration/form/filing four months after after year-end submitted
year-end, same as annually.
income tax return.
Contemporaneous EY and Government resources, links,
requirements: No publications, etc.
CbCR notification N/A N/A N/A
Link to the EY Worldwide Transfer Pricing Link
Reference Guide
Contemporaneous
requirements: No
CbC report N/A N/A N/A
Contemporaneous
requirements: No
Page 26 COVID-19 Response Tracker - Transfer Pricing• Contact: Mary Michalopoulou • Last updated: 21 May 2020
Greece • Contact: Panagiotis Tzanetakis
• Contact: Christos Kourouniotis
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Transfer Pricing obligation type Applicable deadlines per local regulations usually in force New submission deadlines per Covid- Related comments
19-specific measures (if any)
Transfer pricing documentation The transfer pricing documentation file has to be prepared annually No. Persons subject to documentation requirements
up to the deadline for the submission of companies’ CIT return; include taxpayers with a total value of inter-company
while it has to be submitted to the Greek tax authorities within 30 transactions of more than €200,000 or €100,000,
Contemporaneous requirements: No days following their request. depending on whether their turnover is more or less
than €5 million, respectively.
Entities subject to documentation requirements need to
prepare a Master File and a Local File (no threshold
applies).
Transfer Pricing declaration/form/ The SIT must be filed up to the deadline for the submission of No. Taxpayers disclose their intra-group transactions by
filing companies’ corporate income tax (CIT) returns. annually filing electronically a summary information
Contemporaneous requirements: No table (SIT) of transfer pricing information.
CbCR notification Greek tax resident entities forming part of an MNE group that are No. The CbCR requirements that are applicable to Greek tax
subject to the CbCR requirements must notify the AADE of the resident entities that are members of an MNE group
identity and tax residence of the reporting entity no later than the with a consolidated group turnover exceeding €750
Contemporaneous requirements: No last day of the reporting fiscal year. million were introduced by L. 4484/2017.
CbC report Under local rules, the ultimate parent entity (UPE) of an MNE group No. A taxpaying member of an MNE group, which is subject
or any other reporting entity, established in Greece, is required to
submit the CbC report — for each fiscal year — electronically to the to CbCR submission requirements, should release also
Contemporaneous requirements: No competent authority within 12 months from the end of the MNE under Table Θ of its CIT return:
group’s reporting fiscal year.
► The group it belongs to
► Whether it has submitted a CbCR
► The country or tax jurisdiction of the UPE
► The country or tax jurisdiction to which the CbCR
has been submitted
Page 27 COVID-19 Response Tracker - Transfer PricingGreece (continued) Find the most current version of this tracker on ey.com Return to jurisdiction list Are there any COVID-19-related impacts on transfer pricing-specific audits? N/A. Tax audits are continuing remotely. Link to EY Tax Controversy Response Tracker for further audit-specific Link information Have there been any impacts or changes to APAs, Rulings, or other transfer No Covid-19-specific measures applicable to APAs. There is a general slow down in the APA process due to the country’s pricing related certainty measures? response to Covid-19. Implementation of transfer pricing-specific stimulus measures, e.g., safe No harbors? EY and Government resources, links, publications, etc. Link to the EY Worldwide Transfer Pricing Reference Guide Link Page 28 COVID-19 Response Tracker - Transfer Pricing
• Contact: Martin M Richter • Contact: Vicky WK Li • Last updated: 13 May 2020
Hong Kong • Contact: Sangeeth Aiyappa • Contact: Davis Hung
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing obligation type Applicable deadlines per local regulations usually in New submission deadlines per COVID-19-specific measures (if any) Related comments
force
Transfer pricing documentation Preparation deadline: within nine months after the N/A TP documentation submitted upon
end of the accounting period. request.
Contemporaneous requirements: No
Transfer Pricing declaration/form/ filing Supplementary transfer pricing information (“S2 Submission of tax returns that fall between 23 March 2020 and 2 May N/A
Form”) is due with tax return: within one month 2020 are automatically extended to 4 May 2020.
from the date of issue of the profits tax return. [Sourced from Latest arrangements for public services of Inland
Contemporaneous requirements: No
Revenue Department as of 4 April 2020
https://www.ird.gov.hk/eng/ppr/archives/20040401.htm]
CbCR notification Within three months after the end of the UPE’s Submission of CbCR notification for the Hong Kong reporting entities N/A
accounting period. whose UPE’s accounting period ended between 31 December 2019 and
29 February 2020 is on or before 1 June 2020, provided that the
Contemporaneous requirements: No notification is received via the CbCR Portal.
CbC report Within 12 months after the end of the UPE's Submission for CbC report for those Hong Kong entities supposedly due N/A
accounting period. for submission on 31 March 2020 is automatically extended to 6 April
2020.
Contemporaneous requirements: No
Page 29 COVID-19 Response Tracker - Transfer PricingHong Kong (continued)
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Are there any COVID-19-related impacts on transfer pricing- N/A
specific audits?
Link to EY Tax Controversy Response Tracker for further audit- Link
specific information
Have there been any impacts or changes to APAs, rulings, or No.
other transfer pricing related certainty measures?
Implementation of transfer pricing-specific stimulus measures, No.
e.g., safe harbors?
EY and Government resources, links, publications, etc. Latest arrangements for public services of Inland Revenue Department as of 22 March 2020
https://www.ird.gov.hk/eng/ppr/archives/20032201.htm
Latest arrangements for public services of Inland Revenue Department as of 4 April 2020
https://www.ird.gov.hk/eng/ppr/archives/20040401.htm
Country-by-Country Reporting - Notification Deadline as of 27 March 2020
https://www.ird.gov.hk/eng/ppr/archives/20032701.htm
Latest arrangements for public services of Inland Revenue Department as of 4 April 2020
https://www.ird.gov.hk/eng/ppr/archives/20040401.htm
Link to the EY Worldwide Transfer Pricing Reference Guide Link
Page 30 COVID-19 Response Tracker - Transfer Pricing• Contact: Adam Pongo • Last updated: 21 May 2020
Hungary • Contact: Zoltan Liptak
Find the most current version of this tracker on ey.com Return to jurisdiction list
Transfer Pricing Applicable deadlines per local New submission deadlines per Related comments Are there any COVID- No specific pronouncements, but there has
obligation type regulations usually in force COVID-19-specific measures (if 19-related impacts on been a general slowdown due to people not
any) transfer pricing- being able to work at 100% capacity.
specific audits?
Transfer pricing The deadline for the preparation The deadline has been extended to Link to EY Tax
documentation and submission of the TP local file 30 September (except for banks, Link
Controversy
is the filing date of the corporate insurance companies, investment Response Tracker for
tax return (May 31st is the tax year firms and companies on the stock
Contemporaneous coincides with the calendar year). market). further audit-specific
requirements: Yes Deadline for the preparation of information
master file is adjusted to the
ultimate parent company, but 12 Have there been any No specific pronouncements, but there has
months at the latest after the last impacts or changes to been a general slowdown due to people not
day of the tax year. APAs, rulings, or being able to work at 100% capacity.
other transfer pricing
related certainty
measures? The Tax Office expects that some of the
Transfer Pricing N/A N/A previously issued APAs will have to be modified
declaration/form/filing and renegotiated due to the crisis.
Contemporaneous Implementation of The Hungarian government has introduced a
requirements: No transfer pricing- surtax on the retail sector. It decreases the
specific stimulus EBIT (and OM) of the companies subject to the
measures, e.g., safe surtax. The tax office liaise with the Ministry of
CbCR notification All domestic constituent entities of N/A harbors?
MNEs under the scope of CbCR are finance how this surtax should be treated from
required to file a notification until a TP perspective.
Contemporaneous the end of the reporting fiscal year,
requirements: No in which they indicate their filing EY and Government
status. resources, links,
publications, etc.
CbC report If CbCR has to be filed in Hungary, N/A
it shall be submitted within 12
months after the last day of the Link to the EY Link
Contemporaneous financial year reported. Worldwide Transfer
requirements: No Pricing Reference
Guide
Page 31 COVID-19 Response Tracker - Transfer Pricing• Contact: Ankush Mehta • Last updated: 20 May 2020
India • Contact: Heena P Mody
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Transfer Pricing Applicable deadlines New submission deadlines per Related comments Are there any COVID- The Indian Tax Authorities have introduced a
obligation type per local regulations COVID-19-specific measures (if any) 19-related impacts on scheme to provide dispute resolution for pending
usually in force transfer pricing- Income Tax litigation which included Transfer
specific audits? Pricing Litigation as well. The deadline for availing
relief under the scheme has been extended from
30 June 2020 to 31 December 2020.
Transfer pricing The documentation No Transfer Pricing Study Report
documentation should be in place at the to be maintained.
time of filing of Link to EY Tax Link
Accountants Report Controversy Response
Contemporaneous i.e., 31 October 2020. Tracker for further
requirements: Yes audit-specific
information
Have there been any No
impacts or changes to
APAs, rulings, or other
transfer pricing related
Transfer Pricing 31 October 2020 No Mandatory filing of certainty measures?
declaration/form/filing Accountants Report.
Contemporaneous Implementation of No
requirements: No transfer pricing-
specific stimulus
measures, e.g., safe
CbCR notification Two months prior to No Mandatory Required. harbors?
due date of furnishing
of CbCR.
EY and Government
Contemporaneous resources, links,
requirements: No publications, etc.
CbC report 12 months from the The CbC report deadline in India is Mandatory Required by entity
end of relevant 31 March, the same is extended to having consolidated Group Link to the EY Link
accounting year. 30 June 2020. Revenue exceeding INR 5500 Worldwide Transfer
crore in previous accounting Pricing Reference
Contemporaneous year. Guide
requirements: No
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