India: Budget 2018 proposes rules for implementation CbC reporting requirements
On 1 February 2018, the Finance Minister presented the Union Budget 2018. The budget includes proposals to clarify rules for implementation of the country-by-country (CbC) reporting requirements. Consequently, the due date for submits the CbC
See MoreFinland: Tax administration publishes new guidance on TP documentation
On 29 January 2018, the tax administration issued the new guidance No.A129/200/2017 on transfer pricing documentation, which replaces the previous guidance of 2007. The documentation requirement is divided into a master file and a local file. The
See MoreCosta Rica: Tax administration Gazettes CbC reporting resolution
On 2 February 2018, Costa Rica published the Resolution no.DGT-R-001-2018. Resolution No.DGT-R-001-2018 requires multinationals to submit a CbC report in accordance with the OECD's recommendations for the erosion and profit shifting base (BEPS)
See MoreSwitzerland: Federal Council set the parameters for the dispatch on tax proposal 17
The Swiss Federal Council announced that it has set the parameters for the dispatch on the country's tax reform proposal (tax proposal 17) on 31st January 2018. The Federal Council's parameters that will be contained in the dispatch on tax proposal
See MoreSouth Africa: SARS issues draft guide on understatement penalties for public comment
On the 22 January 2018, the South African Revenue Service (SARS) released a draft guide on understatement penalties for public comment by 12 February 2018. The aim of the guide is to provide taxpayers with an understanding of understatement
See MoreSouth Africa: National Treasury issues 2nd draft of the carbon tax bill for public comment
On 14 December 2017, the National Treasury was published the 2nd draft of the Carbon Tax Bill for public comment and presented in Parliament. The version of the second draft law is generally follows the first version (published in 2015) but reflects
See MoreOECD: Platform for Collaboration on Tax to hold global conference
The first global conference of the Platform for Collaboration on Tax (PCT) is to be held on February 14-16, 2018, focusing on important directions for tax policy and administration so as to achieve the Sustainable Development Goals (SDGs). The PCT
See MoreOECD: Updated report on preferential tax regimes
Action 5 of the OECD/G20 action plan on base erosion and profit shifting (BEPS) aimed to counter harmful tax practices more effectively, taking into account transparency and substance. The minimum standard set out in the final report on Action 5
See MoreDenmark increases research and development deduction from 2019
The Danish Government announced on 2 February 2018 that corporate income tax deductions for research and development (R & D) expenses will increase from 100 to 101.5% in 2019. It is expected that the deduction of R & D spending in 2026 will
See MoreOECD: Inclusive Framework issues more guidance on implementation of CbC reporting
On 8 February 2018 the Inclusive Framework issued additional guidance to give on the implementation of country-by-country (CbC) reporting under Action 13 of the OECD/G20 project on base erosion and profit shifting (BEPS). The jurisdictions
See MoreMalaysia: IRBM amends the APA rules and updates the MAP guidelines
Recently, the MIRB (Malaysia Inland Revenue Board) has published an amendment to the APA Rules and the updated Mutual Agreement Procedure (“MAP”) Guidelines. The APA rules referred to as the Income Tax (Advance Pricing Arrangement) Rules 2012
See MoreJapan: Cabinet approves tax reform plans for 2018
Japan's Cabinet has approved a tax reform plan for the next fiscal year and includes a move to cut the corporate tax rate to 25% for companies that raise their employees' wages by 3%. For companies investing in improving their productivity or
See MoreAustralia: Guidelines on attribution of ADI equity capital and controlled foreign entity equity
On 24 January 2018, the Australian Taxation Office (ATO) issued the Practical Compliance Guideline (PCG) 2018/1. This Guideline sets out how the ATO will administer subsection 820-300(3) of the Income Tax Assessment Act 1997 (ITAA
See MoreNigeria: House of Representatives passes Petroleum Industry Governance Bill
The House of Representatives of Nigeria has passed the Petroleum Industry Governance Bill (PIGB) 2017 on January 17, 2018. The PIGB now awaits harmonization by the two Legislative Houses and the assent of the President before it is signed into law.
See MorePakistan: FBR publishes amendments to CbC reporting requirements
On 31 January 2018, the Federal Board of Revenue (FBR) in Pakistan has published SRO no. 99(I)/2018, which provides amendments to draft rules that establish transfer pricing documentation and country-by-country (CbC) reporting requirements for large
See MoreLithuania proposes new transfer pricing rules
On 15 January 2018, a draft order amending the regulations of controlled transactions was issued by the Ministry of Finance of the Republic of Lithuania (to amend the Order No. 1K-123 dated 9 April 2004). The main points in the draft order are the
See MoreIndia: Budget introduces the digital permanent establishment rule
On 1 February 2018, the Finance Minister has released India’s 2018-19 budget and finance bill. The 2018 budget proposed to amend the definition of a permanent establishment for the taxation of non-resident digital companies operating in India.
See MoreIndia: Union Budget introduces the digital permanent establishment rule
On 1 February 2018, the Finance Minister has released India’s 2018-19 budget and finance bill. The budget proposes to update the definition of a permanent establishment (PE) to tax non-resident digital firms operating in India. According to the
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