New Zealand’s taxation act regarding Neutralising Base Erosion and Profit Shifting receives royal assent
New Zealand's Taxation (Neutralising Base Erosion and Profit Shifting) Act received royal assent on 27 June 2018. The main measures of the Act are summarized as follows: CbC reporting requirement: According to the published guidance on
See MorePuerto Rico: Treasury Department defines extended timeline for filing returns 2017
The Treasury Department of Puerto Rico (PRTD) has explained (Informative Bulletin 18-14) the due dates for taxpayers who have submitted automatic renewal filings for filing income tax returns for 2017. Calendar year-end taxpayers who submitted an
See MoreUS: IRS issues new transfer pricing examination guide
On 29 June 2018, Treaty and Transfer Pricing Operations (TTPO) of the Large Business and International (LB&I) division of the IRS released the Transfer Pricing Examination Process (TPEP) for use in transfer pricing examinations. Transfer Pricing
See MoreLuxembourg: Government submits a bill for ratification of the MLI to parliament
On 3 July 2018 the Luxembourg government submitted the bill for ratification of the Multilateral Instrument (“MLI”) to parliament. On 15 June 2018, the Cabinet was approved this bill for ratification of the Multilateral Instrument
See MoreLithuania ratifies multilateral convention to implement tax treaty related measures to prevent BEPS (MLI)
On 14 June 2018, Lithuania ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) by the Law No. XIII-1271, as published in the Official Gazette on 26 June 2018. This means that Lithuania has completed
See MoreIreland publishes tax and duty manual on loans applied in acquiring an interest in a company
On 16 July 2018, Irish revenue authority published a Tax and Duty Manual concerning loans applied in acquiring an interest in a company. The contents of Tax and Duty Manual Part 08-05-02 - Loans applied in acquiring an interest
See MoreOECD: Global Forum issues peer reviews on tax transparency and information exchange
On 16 July 2018 the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes published peer review reports assessing the level of compliance by seven countries with the international standard on tax transparency and
See MorePlatform for Collaboration on Tax: taxation of offshore indirect transfers
On 16 July 2018 the Platform for Collaboration on Tax (PCT) published a new draft of its toolkit on the taxation of offshore indirect transfers of assets. The PCT was set up by the IMF, OECD, UN and World Bank at the request of the G20 of countries
See MoreCanada: CRA publishes 2017 APA Program Report
The Canada Revenue Agency (CRA) has published an annual report on its APA program since the 2001 to 2002 fiscal year. Since 2016, the annual report has been based on a calendar year, whereas the previous annual reports were based on a fiscal year.
See MoreCanada: NRA announces successful first round of CbC report exchanges
The Minister of National Revenue Agency (NRA) has announced that Canada has completed its first round of CbC report exchanges successfully. In this way, Canada has automatic access to more information and data that will allow the Canada Revenue
See MoreU.S. and Indonesia sign an agreement on the exchange of CbC reports
According to an IRS announcement on its website, the competent authorities of the U.S. and Indonesia have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of
See MoreChina declares tax incentive for small enterprises
State Administration of Taxation (SAT) of China has published Circular 77/2018 to extend the tax incentive for small and low-profit enterprises. The incentive provides for a 50% reduction in taxable income with a reduced tax rate of 20%. From
See MoreBrazil clarifies CFC rule regarding exemption for oil and natural gas industry
Private Ruling 4,020/2018 concerning the exemption under CFC rules for profits acquire by the oil and gas industry was published in the Official Gazette on 19th June 2018. The Decision clarifies that the tax exemption of the profits realized is
See MoreAustralia: New guidelines for Local and Master file for 2018
The Australian Taxation Office (ATO) has published Local file instructions 2018 and Local file/master file 2018 to provide guidance for taxpayers to comply. The local file must be electronically lodged in the approved form (an XML file generated
See MoreEcuador: SRI revises deadline to submit tax compliance report
The tax authority of Ecuador (SRI) issued a resolution to extend the deadline for filing the tax compliance report from 1 July 2018 to 28 July 2018, based on the ninth digit of tax identification
See MorePeru: Tax administration issues resolution regarding master file and CbC reporting requirements
The tax administration (Superintendencia Nacional de Administración Tributaria, SUNAT) issued Resolution 163-2018/SUNAT (the Resolution) on 29 June 2018 which was published in the Official Gazette. The Resolution sets out the rules for preparing
See MoreItaly : Law Decree entered into force following its publication
Italy Published Law Decree No. 87 of 12 July 2018 was entered into force following its publication in Official Gazette No. 161 of 13 July 2018. Details of the tax measures are summarized below: Regarding Incentives: Under article 7 of the Law
See MoreAustralia: ATO publishes draft guidance on transfer pricing issues
The Australian Taxation Office (ATO) has issued Draft Schedule 2 to Practical Compliance Guideline (PCG) 2017/1 ATO compliance approach to transfer pricing issues related to centralized operating models involving procurement, marketing, sales and
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