Reporting, Rule Changes and Reversals…

This week we turn to international tax matters, starting with the Finnish Government, which has announced plans to amend various tax laws to strengthen the tax agency's ability to scrutinize and adjust taxpayers' transfer pricing affairs.

The Government explained that the main change will be to the transfer pricing adjustment rules in the Tax Procedure Act, including to provide for more rigorous transfer pricing analyses.

Meanwhile, in India, in the context of the country's recent reversal on its retroactive tax stance, which has impacted on various international tax disputes in which the authorities are embroiled, the Government has released a statement to the effect that it does not intend to pay interest on any tax amounts refunded.

India also recently announced a one-month extension to country-by-country reporting regime deadlines. The CbC report notification, required two months prior to the furnishing of the CbC report, in Form No. 3CEAC, may be filed on or before December 31, 2021, rather than on or before November 30, 2021, the Government stated.

Continuing on the reporting theme, it emerged that West African nation Togo is to join the BEPS Inclusive Framework as its 140th member.

By joining the Inclusive Framework, Togo will participate in the implementation of the various measures recommended by the OECD to tackle tax base erosion and profit shifting. It will contribute towards the development of further measures, along with the other 139 members of the Framework.

And finally, Algeria has become the 163rd member of the Global Forum on Transparency and Exchange of Information for Tax Purposes.

By joining the Global Forum, Algeria has committed to combatting tax evasion through the implementation of the internationally agreed standards of transparency and exchange of information for tax purposes – both exchange of information on request and automatic exchange of information.

Until next week!