OECD considers updating guidance on transfer pricing for intragroup services
The OECD is considering revising the guidance in Chapter VII (intragroup services) of the transfer pricing guidelines. A consultation has been held, for which the closing date for comments was 20 June 2018, and the comments from interested parties
See MoreOECD: Working Party considers revising Chapter IV of the transfer pricing guidelines
The OECD is considering revising the guidance in Chapter IV (administrative approaches) of the transfer pricing guidelines. A consultation has been held, for which the closing date for comments was 20 June 2018, and the comments from interested
See MoreSwitzerland publishes guidance regarding mutual agreement procedure
The Swiss State Secretariat for International Financial Matters has released guidance for mutual agreement procedure (MAP) requests under Switzerland's tax treaties. Switzerland has concluded double taxation agreements with numerous countries.
See MoreOECD: Multilateral Instrument ratified by Serbia
The OECD has reported that on 5 June 2018 Serbia deposited with the OECD Secretary General its instrument of ratification in relation to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting
See MorePakistan enacts Finance Bill 2018
The Finance Bill, 2018 was passed by the government on 22 May 2018, with some amendments. The Bill provides for the implementation of the measures proposed as part of the 2018-2019 Budget. The main measures are summarized as follows: Corporate
See MoreUK: Income tax has increased more for the highest earners
Data issued by the UK tax authority HMRC appears to show that the UK’s highest earners paid 9% more in income tax in 2017/18 than in 2016/17. The main reason for this increase appears to be limits introduced to the amount of tax deduction for
See MoreUK: Government signals that taxes could rise
The UK prime minister has indicated that extra funding to be provided to the health service will be partly raised by tax increases. No comment has been made on which taxes will rise except that this will be done in a fair and balanced way. Part of
See MoreUK: Tax Gap Statistics Published
A press release by the UK government on 15 June 2018 confirmed that the tax gap for 2016/17 was an estimated GBP 33 billion or 5.7%. The tax gap is the difference between the tax that the government considers should have been paid and the actual
See MoreChina reduces tax rate for advanced technology service enterprises
China's Ministry of Finance has published a Circular 44/2018 for reducing corporate income tax rate of 15% (standard 25%) for advanced technology services enterprises with effect from 1 January 2018. This applies in particular for enterprises
See MoreCanada: Budget Implementation Act, 2018, No. 1 receives Royal Assent
The Finance Minister, Bill Morneau, welcomed Royal Assent of the Budget Implementation Act, 2018, No. 1, which implements a number of important measures announced in Budget 2018. The Budget Implementation Act, 2018, No. 1 received Royal Assent on
See MoreBelgium: Notification for corporate tax compliance
As the first half of 2018 almost ends, it is time to look forward to the coming second installment of prepayments. Income tax returns The income tax authorities confirmed the deadline of the filing of corporate income tax returns with a financial
See MoreAustralia: Draft PCG for Restructures of Hybrid Mismatch Arrangements
As part of the 2016-17 Federal Budget, the Australian government announced it would implement the Organisation for Economic Co-operation and Development's (OECD) Hybrid Mismatch rules developed under Action Item 2 of the OECD Base Erosion and Profit
See MoreChile: Reminder about the due date of submitting Sworn Statement of Income
The Internal Revenue Service (SII) gives a reminder to taxpayers of the due date of five Affidavit of Income. These are Forms No. 1929, 1930, 1907, 1937 and 1945, which are explained below: Sworn declaration Expiration date Form No. 1907 on
See MoreGreece: Public revenue Authority publishes a circular on MCAA
The Public Revenue Authority has published a Circular on June 15, 2018 regarding the lists of jurisdictions with which Greece wants implement the Multilateral Competent Authority Agreement on the exchange of Country-by-Country (CbC)
See MoreNigeria: FIRS publishes Income Tax (CbC Reporting) regulations
The Federal Inland Revenue Service (FIRS) has released the Income Tax (Country-by-Country Reporting (CbCR)) Regulations on June 19, 2018. It was published in an official gazette on January 8, 2018. This CbCR Regulations give guidelines to
See MoreUruguay: Parliament passes a bill on the Multilateral Instrument (MLI)
4 June 2018, the Uruguayan parliament passed the Bill for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Uruguay signed the MLI on 7 June 2017. The MLI will
See MoreIndia: No international transaction with related party in the absence of an agreement with the AE
Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (the Tribunal) ruled its decision on the transfer pricing (TP) case of Colgate Palmolive (India) Ltd. v. ACIT (ITA No. 6073/Mum/2014 and ITA No. 2778/Mum/2011) in favor of the taxpayer.
See MoreIndia: The expenditure specifically incurred for Indian taxpayers’ market cannot be construed to benefit the AE
On 14 May 2018, the Delhi Bench of the Income-tax Appellate Tribunal ruled its decision on the transfer pricing (TP) case of BMW India Pvt. V. ACIT (ITA No 6160 / Del. / 2014) in favor of the taxpayer. The court held that, expenses that are
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