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October 8, 2021
2021-1831

Jordan issues transfer pricing instructions

On 16 September 2021, the Hashemite Kingdom of Jordan published Executive Instructions No. (3) of 2021 (the Instructions) in the Official Gazette. The Instructions provide further details on the application of the new transfer pricing (TP) rules that became effective in July 20211 and also prescribe the forms that taxpayers should use for filing the TP Disclosure and the Country-by-Country (CbC) report.

The Instructions do not specify when taxpayers need to start complying with the new rules. It also appears that taxpayers are expected to file a copy of the full CbC report in Jordan, even if the original is filed outside Jordan by an Ultimate Parent Entity or a Surrogate Parent Entity.

In the absence of further guidance from the Income and Sales Tax Department (ISTD), for any reporting period ending after 7 July 2021:

  • Taxpayers engaged in transactions with related parties (including notional transactions between a branch and its head office) with an annual value exceeding JOD500,000 (approximately US$705,000) will need to:
    • Submit a TP Disclosure to the ISTD with the tax return (i.e., within four months from the taxpayer's year-end).
    • Prepare and submit TP master and local files within 12 months following the end of the tax reporting period.
  • Members of a multinational enterprise (MNE) group with consolidated revenue exceeding JOD600m (approximately US$846m) will need to submit a CbC report to the ISTD within 12 months following the end of the MNE group's tax period.

Jordan-based entities should start reviewing their TP policies and related-party pricing arrangements so they will be able to meet their compliance requirements on a timely basis.

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For additional information with respect to this Alert, please contact the following:

Ernst & Young Jordan, Amman

Ernst & Young LLP (United States), Middle East Tax Desk, New York

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ENDNOTE

  1. See EY Global Tax Alert, Jordan implements transfer pricing rules, dated 21 June 2021 for previous coverage.
 

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