Portugal: General rule for CbC reporting requirement: Portugal has introduced Country-by-Country (CbC) reporting requirement for domestic entities with consolidated group revenue of €750 million or more for an accounting period. The CbC report is a new requirement for the Portuguese parent company of a multinational enterprise (MNE) group, provided that the parent company is not itself owned by a foreign related party that is obliged to submit the CbC report. The regulations will apply to multinational groups for accounting periods beginning on or after 1 January 2016.
Parent company: The Country-by-Country (CbC) report must be submitted by a company resident in Portugal that is the parent company of a corporate group. A parent company is a company that is not a subsidiary of any other company in Portugal.
Group definition: The country by country reporting requirement applies where the consolidated group revenue in the preceding year exceeded €750 million.
Profits and tax paid: The report must cover group revenue, distinguishing between related and unrelated parties; accounting results before corporate income tax (or similar taxes); and corporate tax (or similar taxes) paid or accrued, including withholding tax.
Employees: The average number of employees in each entity must be reported.
Assets: Tangible assets and real estate interests.
Timing: The CbC report must be submitted within twelve months after the end of the tax year.
Penalty for non-compliance: Failure to submit the CbC reporting before the due date defined by the Tax and Customs Authority will result in a penalty which can reach €20,000 per year and per company.
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Japan: BEPS related compliance:
Master file information: Japan has introduced a requirement for a master file for multinational group with consolidated group revenue of JPY 100 billion or more for the preceding fiscal year. A Japanese company which is the constituent entity of a multinational group and a permanent establishment (PE) of non-Japanese companies should submit the master file for fiscal years beginning on or after 1 April 2016. Master file will contain information regarding description of the group’s capital structure, transfer pricing policy and significant intangible assets utilized.
Reporting structure: In line with the Action 13 of OECD Base Erosion and Profit Shifting (BEPS) project.
Local file information: Japan has introduced a requirement for a local file in line with the OECD Base Erosion and Profit Shifting (BEPS) project from 1 April 2017. A Japanese company and a PE of a non-Japanese company which have conducted transactions with foreign related parties must prepare the local file on a contemporaneous basis. A local file will contain specific transfer pricing information for each relevant country of operation.
General rule for CbC reporting requirement: Japan has introduced Country-by-Country (CbC) reporting requirement for domestic entities with consolidated group revenue of JPY 100 billion or more for the preceding fiscal year. A Japanese company which is the ultimate parent of a multinational group and companies not submitting in a country with a tax treaty with Japan must submit a CbC reporting for fiscal years beginning on or after 1 April 2016.
Parent company: The Country-by-Country (CbC) report must be submitted by a company resident in Japan that is the parent company of a corporate group. A parent company is a company that is not a subsidiary of any other company in Japan.
Group definition: The country by country reporting requirement applies where the consolidated group revenue in the preceding year exceeded JPY 100 billion.
Profits and tax paid: The report must cover group revenue, distinguishing between related and unrelated parties; accounting results before corporate income tax (or similar taxes); and corporate tax (or similar taxes) paid or accrued, including withholding tax.
Employees: The average number of employees in each entity must be reported.
Assets: Tangible assets and real estate interests.
Timing: The CbC report must be submitted within twelve months after the end of the tax year.
Penalty for non-compliance: The tax reform in Japan implements penalties for a failure to file the CbC report by the due date. The exact nature of these penalties and to whom they apply will be clarified in a later Order or Directive.Main corporate tax rate: The national corporate tax rate has been reduced to 23.4% from 23.9% for taxable years beginning on or after 1 April 2016. A further reduction of corporate tax rate to 23.2% will be applicable for taxable years beginning on or after 1 April 2018.

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South Africa: General rule for CbC reporting requirement: The South African Revenue Service (SARS) published draft regulations on 11 April 2016 concerning a country-by-country (CbC) reporting standard for multinational enterprises. South African MNEs with annual group consolidated turnover exceeding ZAR 11.5 billion in the 2015 financial year will be required to prepare the CbC report for financial years starting on or after 1 January 2016. The reporting deadline is 12 months from the end of the financial reporting year; therefore, the first reporting period for a South African MNE with a 31 December year-end will be 1 January-31 December 2016, with the report due to the SARS by 31 December 2017.
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India:  Comparable data: The Bangalore Bench of the Income-tax Appellate Tribunal gave verdict in the case of ACIT v. McAfee Software (India) Pvt Ltd, [IT(TP)A No. 1388/Bang/2011 and IT(TP)A No. 04/Bang/2012] on factors such as functional comparability that are to be used and described related-party transaction filters and that are to be considered in the selection of comparable companies. The tribunal held that various filters are required in selecting comparable companies and that a turnover filter is to be adopted to avoid the selection of “high-end companies” (big companies) to compare to “minnows” in a similar line of business. Accordingly, a factor to be considered is the turnover or receipts of the taxpayer and the range of the upper limit at 10 times as well as the lower limit at 10 times (i.e., one-tenth with a margin of variation).
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Financial services: The Mumbai Bench of the Income-tax Appellate Tribunal held in the case of India Debt Management Pvt. Ltd. v. DCIT [IT(TP)A No. 7518/Mum/2014 that the selection of a “tested party” is to be made with reference to the entity that has undertaken the transaction and the rate of interest on related-party debt instruments or other borrowings must be market-determined and at arm’s length and must be reported in the currency in which the loan was made or repaid.
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Switzerland: General rule for CbC reporting requirement: The Swiss Federal Council has published draft legislation on country-by-country (CbC) reporting for tax purposes. As per the draft legislation, CbC reporting obligations shall apply to Swiss headquartered multinational groups with annual consolidated group revenue of at least €750m, which equals CHF 900m. It is expected that the new law will enter into force effective from the fiscal years beginning on or after 1 January 2018.
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Russia: General rule for CbC reporting requirement: The Russian Finance Ministry issued a draft law on 8 April 2016 regarding the introduction of country-by-country reporting in Russia. The CbC reporting requirements would apply only to international groups whose aggregate revenue according to consolidated financial statements for the financial year immediately preceding the financial year for which a CbC report is submitted exceeds 50 billion rubles. The CbC reporting requirements would apply to financial years commencing from 1 January 2017.
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Malaysia: CbC reporting requirement: The Malaysian Inland Revenue Board has announced plans to introduce Country-by Country (CbC) reporting requirement and to update current local transfer pricing documentation requirements to include the Master File and Local File concepts in line with Action 13 of the OECD BEPS project. The CbC reporting and new transfer pricing documentation requirements are expected to be effective in Malaysia from 1 January 2017.
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Chile:  Annual return of global tax characterization: The Chilean IRS established an obligation to submit an Annual Return of Global Tax Characterization (affidavit F.1913) through Resolution No. 110 issued on December 24, 2015.
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Tanzania: Documentation requirement: Tanzanian regulations require taxpayers with related-party transactions to have contemporaneous transfer pricing documentation in place before filing a final tax return.
Penalty for documentation failure: The Regulations impose a penalty of not less than 50 million Tanzanian shillings (approximately USD 23,000) for non-compliance with the transfer pricing documentation requirement.
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UK: Transfer pricing rule: The UK budget for 2016-17 includes an update of the transfer pricing guidelines in line with OECD Guidelines. This measure amends from 1 April 2016 the references within the relevant legislation to incorporate the most recent revisions to the OECD Guidelines which are the internationally agreed standard for application of the arm’s length principle for transfer pricing purposes.
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Greece: Penalty in case of adjustment: As per Law 4337/2015, additional tax between 5% and 20% of the tax amount resulting from transfer pricing adjustment on the basis of the initial tax return may trigger penalty of 10% on the difference and additional tax greater than 20% but less than 50% of the tax amount resulting from transfer pricing adjustment give rise to penalty of 25% on the difference. If additional tax is greater than 50% of the tax amount resulting from transfer pricing adjustment on the basis of initial tax return then the penalty will rise to 50% on the difference.
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Turkey: Cost contribution arrangement (CCAs): Definition and guidance on cost contribution arrangements (CCAs) has been introduced in Turkey by a new Draft General Communiqué numbered 3 on Disguised Profit Distribution through Transfer Pricing.
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Ecuador: Comparable Uncontrolled Price (“CUP”) method: The Executive Decree 973 issued by the president of Ecuador eliminates the application of the CUP method for import and export transactions with public and well-known international prices and the CUP Method for import and export transactions through an international intermediary.
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