Italy: CbC Reporting requirement-Timing: On December 11, the tax authority issued a Measure no. 288555 extending the due date for filing the CbC report for fiscal year 2016 from 31 December 2017 to 9 February 2018 within 60 days following the measure’s publication date.
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Bulgaria: Information Exchange-Multilateral: Bulgaria has signed the Multilateral Competent Authority Agreement (MCAA) on 17 November, 2017 for the exchange of country by country reports under action 15 of the OECD’s BEPS project.
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Portugal: CbC Reporting Requirement-Timing: CbC reporting form 54 has been approved by Order No. 367/2017 dated 11 December 2017. The form must be submitted electronically every year in respect of fiscal periods starting as from 1 January 2016 within 5 months after the end of the fiscal period concerned.
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Canada: CbC Reporting Requirement-Timing: According to subsection 233.8(6) of the Act, the CbC report for the fiscal year ended December 31, 2016, must be filed with the CRA no later than December 31, 2017. However, if notification of systemic failure has been received by the constituent entity (CE) of a multinational enterprise (MNE) groups, this deadline can be extended to 30 days after receipt of the notification.
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Argentina: Main Corporate tax rate: As per the draft tax reform bill which was submitted to Congress on 14 December 2017, the corporate income tax rate would decrease from 35% to 30% for fiscal years starting 1 January 2018 to 31 December 2019, and to 25% for fiscal years starting 1 January 2020 and onwards.
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China: CbC reporting requirement-General rule: On 19 December 2017, the State Administration of Taxation (SAT) issued a public notice no. 46 explaining the CbC reporting related issues. According to the notice, Articles 7 and 8 of public notice no. 42 concerning the submission of related party transactions and administration of contemporaneous transfer pricing documentation are not applicable to CbC reporting for 2016.
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Denmark: CbC reporting requirement-Timing: On 21 December 2017, the Danish Tax and Customs Administration issued press release No. 17-1975627 on CbC reporting. The press release recalls that Danish companies, which are part of a multinational group with a turnover of DKK 5.6 billion, will submit a 2016 report by the end of 2017.
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Documentation-Deadlines: On 7 December 2017, the Danish Parliament enacted Bill No. L 13 establishing a deadline for the preparation of Danish transfer pricing documentation. Danish taxpayers are required to prepare transfer pricing documentation in line with OECD guidelines and must be submitted to the tax authorities within 60 days of a request.
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Finland: CbC reporting requirement-General rule: On 19 December 2017, Bill No. 191/2017 was submitted to the parliament as a proposal to amend section 14 d of the Act on Taxation Procedure which is in line with Council Directive (EU) 2016/881 of 25 May 2016 amending Directive 2011/16/EU.
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Ireland: CbC reporting requirement-Timing: The CbC Reporting filing facility will remain open for, and accept, CbC Reports for fiscal years ending in 2016 up to 28 February 2018.
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Russia: CbC reporting requirement: The Federal Tax Service (FTS) publishes country-specific reporting (CbC) formats and a report on participation in multinational enterprise groups on its official website. The new forms comply with BEPS Action 13 requirements for CbC and transfer pricing documentation.
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Information exchange-Multilateral: On November 28, 2017, Federal Law No. 340-FZ of November 27, 2017 was published on the official Internet portal. The law changed the tax code in relation to the implementation of the international automatic exchange of financial accounting information and transfer pricing documentation of multinational companies.
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Colombia: CbC reporting requirement-Timing: On 15 December 2017, Decree 2120 of 2017 has been published that specifies the responsibility for Colombian taxpayers of notification of the filing of the Country by Country Report.
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Cyprus: CbC reporting requirement-Timing: On 11 December 2017, the Cyprus Tax Department issued two notices with extensions of the deadline for submission of CbC reports for the fiscal years 2016 and 2017.
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Greece: CbC reporting requirement: The Public Revenue Authority (AADE) published a guide to frequently asked questions (FAQs) on December 15, 2017 for describing clarifications on the country-by-country (CbC) reporting. This guide explains the step by step process and obligatory items of submitting CbC Reports and also declares penalties for non-compliance with the CbC reporting requirements.
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New Zealand: Financial services- Special rules for hybrid instruments or entities: A tax bill which will counter Base Erosion and Profit Shifting (BEPS) by multinational companies has been introduced into Parliament on 6th December 2017. The Bill contains measures which will prevent multinationals from using hybrid mismatch arrangements that exploit differences between countries’ tax rules to achieve an advantageous tax position.
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Romania: CbC reporting requirement-General rule: On 11 December 2017, the Romanian National Tax Administration Agency published on its website the electronic forms of the CbC report and the CbC report notification templates to be used for submission by the Romanian taxpayer forms R404 and R405, respectively.
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Malta: Requirements-Control: On 6 December 2017, the Minister for Finance adopted the regulations of “Cooperation with other Jurisdictions on Tax Matters (Amendment) Regulations, 2017”. The Regulations introduced the concept of “beneficial owner”. In the case of an entity, the beneficial owner is the person who ultimately owns or controls that body corporate through a direct or indirect ownership of at least 25% plus one of the shares or ownership interests.
CbC reporting requirement-Timing: The CbC report submission deadline has been permanently set to 12 months from the last day of the fiscal year (previously 9 months).
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