Australia updates MAP guidance
The Australian Taxation Office (ATO) has updated its guidance on the mutual agreement procedure (MAP) framework contained in tax treaties to resolve disputes. The new guidance represents an update on Taxation Ruling TR 2000/16 Income tax:
See MoreTransfer Pricing Brief: October 2018
Israel Priority of Methods: According to Circular 11/2018 published on 5 September 2018, in case of sales activity that is performed without significant marketing intangibles, the most appropriate transfer pricing method according to the ITA is
See MoreNigeria: FIRS issues public notice regarding deadline set for TP documentation
The Federal Inland Revenue Service (FIRS) has previously released the Income Tax (Transfer Pricing) Regulations, 2018, which replaced the Income Tax (Transfer Pricing) Regulations, 2012. The 2018 TP Regulations, which introduced supplementary
See MoreThailand: National Legislative Assembly publishes revised draft transfer pricing act
On 27 September 2018, National Legislative Assembly released the revisions to the draft Transfer Pricing Act (the draft TP Act). The revenue threshold for subject to transfer pricing documentation is THB200 million (US$6 million) per year
See MoreZambia: Finance Minister presents National Budget 2019
On 28 September 2018, Zambia’s Minister of Finance, Hon. Margaret Mwanakatwe presented the 2019 National Budget to Parliament. The time period for making transfer pricing assessment may be raised for a period exceeding 6 years but not exceeding 10
See MoreEl Salvador: DGII updates transfer pricing information return and guidelines
On 1 October 2018, the Tax Authority (General Office of Internal Revenue ) updated the new version of the “Report on Operations with Related Parties (Form F-982v4),” whose method of filing is now changed from manual filing to online filing and
See MoreIMF report comments on the economy of the United Arab Emirates
On 30 September 2018 the IMF published a report following consultations with the United Arab Emirates under Article IV of the IMF’s articles of agreement. The IMF expects economic growth to strengthen in the next few years supported by higher oil
See MoreIMF report comments on the economy of Kazakhstan
On 16 September 2018 the IMF published on its website a report following consultations with Kazakhstan under Article IV of the IMF’s articles of agreement. Kazakhstan’s economic growth has strengthened owing to higher oil production and
See MorePeru introduces GAAR, new thin capitalization rule, definition of PE, and Other Changes
On 13 September 2018, the Peruvian government has published Legislative Decree No. 1422 and Legislative Decree No. 1424, which include measures for the implementation of the General Anti-Avoidance Rule (GAAR), new thin capitalization and interest
See MoreSweden:The Administrative Court approves the position of the tax administration on interest on withholding tax refunds
Recently, the Swedish Tax Agency issued a notice concerning a ruling by the Supreme Administrative Court stating that recipients of dividends on which taxes have been levied are entitled to interest if the tax is later refunded. The notice notes
See MoreQatar: MoF implements new CbC requirements through Decision No. 21 of 2018
The Ministry of Finance published a Decision No. 21 of 2018 on September 9, 2018 in the Official Gazette. This Decision implements new Country-by-Country (CbC) reporting requirement. It is effective from September 10, 2018. A CbC report contains
See MoreUK: Statistics on Uptake of Patent Box Relief
From 1 April 2013 the UK phased in Patent Box legislation that allows companies to apply a lower rate of corporation tax to profits earned from patented inventions and other similar forms of intellectual property (IP). The relief was initially
See MoreUS: IRS proposes to withdraw section 385 documentation regulations
On 21 September 2018, IRS published a document proposing to remove Section 385 from treasury regulation that was finalized in the last of the 2016. The regulations require multinationals that issue related-party debt to provide information to the
See MoreUK: Date of autumn budget 2018 announced
The UK has announced that the autumn budget proposals will be announced on 29 October 2018. The date is earlier than in previous years and appears to have been moved forward to avoid coinciding with important talks on Brexit that take place in
See MoreMultilateral Convention (MLI) signed by Saudi Arabia
Saudi Arabia signed the Multilateral Convention on 18 September 2018 to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) bringing the total number
See MoreAustralia: ATO publishes Diverted profits tax guidance
The Australian Tax Office (ATO) published the final form of the Practical Compliance Guideline (PCG) 2018/5 Diverted profits tax (DPT) and Law Companion Ruling (LCR) 2018/6 Diverted profits tax. The PCG aims to assist affected clients and their
See MoreUS: IRS issues reminders relating to Form 8975 of CbC reporting
On 18 September 2018, IRS published a release reminding MNE groups on the processes of filing country-by-country reports on Form 8975. Reminder to U.S. MNEs Filing Form 8975 with no U.S. Schedule A (Form 8975) When submitting Form 8975 and Schedules
See MoreNetherlands: Budget Proposals 2019
On 18 September 2018, the government of Netherlands presented the 2019 budget proposals to the House of Representatives. Implementation of ATAD measures The Proposals put forward legislation that introduces various EU Anti-Tax Avoidance Directive
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