Denmark: Publishes new guidelines on TP documentation

January 31, 2017

The Minister of Taxation issued order BEK no. 401 and 402 regarding transfer pricing documentation. The new documentation guidelines BEK no. 402 will replace the previous guidelines of BEK no. 42. The new guidelines include more specific

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7 more countries sign tax co-operation agreement to enable BEPS Action 13

January 31, 2017

According to a press release of 27 January 2017, published by the OECD, as part of continuing efforts to boost transparency by multinational enterprises (MNEs), Gabon, Hungary, Indonesia, Lithuania, Malta, Mauritius and the Russian Federation have

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India announces GAAR will be effective from April 1, 2017

January 31, 2017

On 27 January 2017, the CBDT has issued Circular No. 7 of 2017 and provided important clarifications on the implementation of GAAR which are to come into force from 1 April 2017. The Circular provides clarifications, considering the comments of the

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Canada: Trump Import Tariffs impact

January 31, 2017

The US President gave warning of raised import tariffs on Mexican exports to the United States. He also made an indication that Canadian exports could be subject to the same tax treatment. He said that he would impose 35% import tariff from

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Lithuania, Russia signed the Multilateral Competent Authority Agreement for CbC reporting

January 31, 2017

According to a press release of 27 January 2017, published by the OECD, Lithuania, Mauritius, Gabon, Hungary, Indonesia, Malta, and the Russian Federation have now signed a tax co-operation agreement, the Multilateral Competent Authority Agreement

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Finland: E-services rule to reduce VAT refund fraud

January 31, 2017

The Finnish government is going to add e-service rule in value added tax system from February 1 to mitigate the VAT refund fraud. Taxpayers who are registered for value-added tax must use the MyTax e-service when providing their bank account

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South Africa: SARS issues tax exemption guide for public benefit organization

January 31, 2017

The South African Revenue Service (SARS) has issued a tax exemption guide on the income tax exemption for a public benefit organization (PBO) carrying on a public benefit activity (PBA). The guide provides general guidance on approval and taxation

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UK: Draft legislation for corporation tax loss reform

January 31, 2017

On 26 January, draft legislation has published by the Government of UK on the reform of the Corporation Tax loss relief rules. This reforms the tax treatment of certain types of carried-forward loss for corporation tax purposes. The legislation

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Japan: Published Frequently Asked Questions regarding transfer pricing documentation requirements

January 30, 2017

Japan’s National Tax Agency (NTA) has issued Frequently Asked Questions (FAQs) regarding transfer pricing (TP) documentation requirements in Japan. It addresses those questions that are likely to be of most interest to overseas headquartered

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TIEA between Australia and Switzerland enters into force

January 30, 2017

The Tax Information Exchange Agreement between Australia and Switzerland was concluded through an exchange of notes entered into force on 1 January 2017. Furthermore, this agreement was signed on 14 December 2016 by Australia and on 8 December 2016

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Germany: Government plans to limit the royalty deductions as from 2018

January 30, 2017

The Federal Ministry of Finance recently approved a draft bill on the limitation of the deduction of royalties on 25 January 2017. The bill focused on foreign IP boxes incompatible with the OECD nexus approach, and to make their use

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Nigeria: FIRS issues new TP declaration and disclosure forms

January 30, 2017

The Federal Inland Revenue Service (FIRS) of Nigeria published new transfer pricing (TP) forms (TP Declaration Form and TP Disclosure Form). This is aimed at improving disclosure and transparency by taxpayers in their TP Returns, and providing FIRS

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India: Union Budget 2017 to be presented on February 1

January 30, 2017

A senior government official said on 19 January 2017, the Indian Government will present the Union Budget for 2017­-18 on February 1, for the financial year starting on 1 April 2017. The first part of the budget session of parliament will start on

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South Africa-Zimbabwe DTA enters into force

January 30, 2017

The Double Tax Agreement (DTA) between South Africa and Zimbabwe entered into force on 1 December 2016, following publication in the Official Gazette of the Republic of South Africa on 27 January 2017. The agreement will be applied from 1 January

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US: IRS launches tax filing season for 2017

January 30, 2017

The US Internal Revenue Service (IRS) launched the 2017 tax filing season on 23 January 2017. Taxpayers have until April 18, 2017, to file their 2016 tax year returns and pay any taxes due. The deadline is later this year than the usual April 15,

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Ecuador introduces new TP regulations to exports

January 29, 2017

The Internal Revenue Service of Ecuador has issued a Resolution that was published in the official gazette on 30 December 2016. The Resolution launches transfer pricing (TP) regulations applicable to exports of bananas, oil, petrol, gold, silver,

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Australia releases guidance on related-party marketing hubs

January 29, 2017

On 16 January 2017, the Australian Taxation Office (ATO) issued a Practical Compliance Guideline which sets out the ATO's compliance approach to transfer pricing issues related to the location and relocation of certain business activities and

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Belgium adopted TP documentation

January 29, 2017

The transfer pricing documentation structure has been implemented in Belgium proposed by the Organisation for Economic Cooperation and Development (OECD). In accordance with the guidance of OECD under Action plan 13, Belgium initiated transfer

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