Greece: Main corporate tax rate: According to Law 4472/2017 published in the official Gazette on 19th May 2017, the corporate income tax (CIT) rate will be reduced from 29% to 26% from 1 January 2019 subject to certain conditions.
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Netherlands: Information exchange-Multilateral: On June 2, 2017, a Bill to implement EU directive 2016/881 was published in official Gazette No. 215. The Bill takes effect from 5 June 2017, with retroactive effect to 1 January 2016. In addition, on June 7, 2017, Netherlands signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS).
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Pakistan: Main corporate income tax rate: According to Federal Budget and Finance Bill for fiscal year 2017-2018, the corporate income tax rate will be reduced from 31% to 30% for tax year 2018.
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Audit Rules-Rules: Pakistan’s Finance Minister presented to Parliament on 26 May 2017 the federal budget for 2017-18. The related finance bill includes provisions establishing an office responsible for conducting transfer pricing audits (Directorate-General of Transfer Pricing) and proposes penalty provisions with respect to certain taxpayer failures such as the failure to maintain or produce transfer pricing documentation and the failure to furnish a timely country-by-country report.
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Lithuania: CbC reporting requirement-General rule: On 23 May 2017, the Lithuanian Parliament passed amendments to the Tax Administration Law to implement the CbC reporting requirements that will take effect from 5 June 2017. According to law, all Lithuanian tax resident entities that are part of an MNE Group with annual consolidated group revenue of €750 million and above will need to comply with the CbC requirements for fiscal years starting on or after 1 January 2016.
CbC reporting requirement-Timing: The CbC report must be submitted within 12 months after the end of MNE’s financial year. There is no information yet regarding the CbC reporting notification deadlines, secondary filling procedures or penalties specific to non-compliance with the CbC requirements.
Penalty for non-compliance: Penalties ranging between €150 and €300 will apply for noncompliance.
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Portugal: CbC reporting requirement-Timing: The CbC report must be submitted within twelve months after the end of the tax year. As per published Decree no. 170/2017-XXI dated May 30, 2017, the deadline to submit the mandatory CbC reporting notification, with respect to the fiscal year 2016, has been extended to 31 October 2017.
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Romania: CbC reporting requirement-General rule: On 24 May 2017, the Romanian Ministry of Finance published a draft law to implement CbC reporting. According to the draft law, all Romanian tax resident entities that are the ultimate parent entity of an MNE Group with annual consolidated group revenue of €750 million and above will need to comply with the CbC requirements for fiscal years starting on or after 1 January 2016.
CbC reporting requirement-Parent company: The Country-by-Country (CbC) report must be submitted by a company resident in Romania that is the parent company of a corporate group.
CbC reporting requirement-Timing: The CbC report must be submitted within 12 months after the end of MNE’s financial year.
Penalty for non-compliance: According to a draft law published on 24 May 2017,  monetary penalties (of up to RON 50,000 – 100,000) could be triggered when a Romanian entity fails to report the required information within the time stipulated or fails to report the information in a complete and accurate manner.
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Costa Rica: Specific TP compliance-Form: Resolution DGT-R-28-2017 of 5 June 2017 modifies Article 4 of Resolution DGT-R-044-2016 and temporarily suspends the due date for filing the transfer pricing information return.
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India: Adjustments-Secondary adjustment: India’s Finance Act, 2017 (FA 2017) introduced “secondary transfer pricing adjustment” provisions in the Indian Tax Law (ITL) to ensure that profit allocation between the associated enterprises (AEs) is consistent with the primary transfer pricing adjustment.
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Safe Harbour-Rule: On 7 June 2017, the Indian Central Board of Direct Taxes revised the existing Safe Harbour Rules (SHRs) which were issued in September 2013. The revised SHRs are available for transactions up to INR 200 crore (approximately USD 31m). The revised SHRs are aimed at reducing Transfer Pricing disputes and providing better certainty to taxpayers.
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Comparability analysis: The Ahmedabad Bench of the Income-tax Appellate Tribunal held in the case Inductotherm (India) Pvt. Ltd v. DCIT that the “internal cost plus method” could not be applied to benchmark exports of finished goods to a related party when there are differences in the geographical location of the market and in the value chain and utility of the product.
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Sweden: Financial services-Restriction on interest deduction: On 20 June 2017, the Swedish Government announced a memorandum proposing new interest deduction limitation rules. Under the rules, the deductibility of the net interest expense would be limited to 35% of taxable EBIT under the main proposal, while a limitation to 25% of taxable EBITDA is presented as an alternative, recognizing that there are advantages and disadvantages to both alternatives.
Main corporate income tax rate: On 20 June 2017, the Swedish Government announced a memorandum proposing corporate tax reduction rate from 22% to 20%.
Safe Harbour-Simplified interest rates: According to a proposed memorandum announced by the government on 20 June 2017, each company in a group may elect to apply a safe-harbor rule allowing a deduction of net interest expense of SEK 100,000 (approx. €10,000).
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