Spain issues amending CIT return and CbC reporting forms
On 14 September 2018, Spain published Order HAC/941/2018 of 5 September 2018 in the Official Gazette. Orders modified the regulate Form 202 (split payment of Corporation Tax and Income Tax for Non-Residents permanent establishments
See MoreNigeria: FIRS publishes a public notice regarding CbC Regulations
The Federal Inland Revenue Service (FIRS) issued a public notice on September 17, 2018. This notice provides alert that income tax country-by-country (CbC) reporting regulations S.I. no. 6, 2018 entered into force with effective from January 1, 2018
See MoreIMF report looks at Chile’s economy and tax reforms
On 20 September 2018 the IMF issued a report on the economic position of Chile following consultations under Article IV of the IMF’s articles of agreement. Chile has experienced strong economic growth in 2018 and is expected to reach around 4%
See MoreEU: Tax Rulings Issued by Luxembourg were not State Aid
On 19 September 2018 the European Commission determined that the non-taxation of certain profits arising to McDonald's Europe Franchising in Luxembourg did not amount to illegal State aid. The Commission had investigated under EU State aid rules
See MoreOECD: Effective Carbon Rates 2018
On 18 September 2018 the OECD issued the publication Effective Carbon Rates 2018: Pricing Carbon Emissions through Taxes and Emissions Trading. The report presents date on taxes and tradeable permits for carbon emissions in 42 countries from the
See MoreOECD: Comments published on discussion draft on transfer pricing for financial transactions
On 18 September 2018 the OECD published comments received on its discussion draft on financial transactions in relation to BEPS actions 8 to 10 (ensuring that transfer pricing outcomes are in line with value creation). Discussion draft The
See MorePeru: Added new thin Capitalization Rules and Amended Income Tax Law
Peru’s President enacted Legislative Decree 1424 on 13 September 2018, which amends the income tax law with regard to the thin capitalization rules, the indirect transfer of shares, the definition of permanent establishment (PE) and the indirect
See MorePoland updates TP reporting regime
The Polish Ministry of Finance has announced on the e-Deklaracje website interactive forms to be used as transfer pricing (TP) reports. Beginning 1 January 2017, taxpayers that transacted or engaged in other operations with related parties of a
See MoreOECD: Inclusive Framework issues further guidance on CbC reporting
On 13 September 2018 the OECD’s Inclusive Framework released additional interpretative guidance in relation to Country-by-Country (CbC) reporting under Action 13 of the OECD/G20 report on base erosion and profit shifting (BEPS). More than 100
See MoreIsrael and Lithuania both complete ratification of BEPS MLI
Israel and Lithuania have ratified a multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). This means that both countries have completed the domestic process and deposit its ratification instrument for MLI. This
See MoreIMF report looks at UK economy
On 17 September 2018 the IMF issued a report following discussions with the UK under Article IV of the IMF’s articles of agreement. Economic growth in the UK has decreased since the EU referendum in June 2016 owing to uncertainty in relation to
See MoreOECD: Tax Policy Reforms 2018
On 14 September 2018 the OECD issued Tax Policy Reforms 2018, summarizing the tax policy reforms carried out in the year by OECD countries and by Argentina, Indonesia and South Africa. Corporate income tax The report notes that significant tax
See MoreSweden: Tax Authority releases updated guidance on hard-to-value intangibles
On 13 September 2018, the Swedish tax authority published an update of transfer prices guidance on intangible assets consistent with OECD's difficult-to-measure intangible assets (HTVI) guidance. The OECD HTVI Guidance offers tax authorities with a
See MoreUS: IRS publishes draft form regarding the “base erosion and anti-abuse tax” (BEAT)
On 5 September 2018, the United States (US) Treasury and the Internal Revenue Service (IRS) released a draft of Form 8991 concerning the “base erosion and anti-abuse tax” (BEAT) reporting for 2018. In an effort to " level the playing field
See MoreBrazil: Administrative Council of Tax Appeals approves validity of resale price method (PRL 60)
The Administrative Council of Tax Appeals (CARF) issued binding decision 115 (Súmula no. 115) on 11 September 2018. The new decision approving that, the calculation method of the ' 60% Profit Price Less Profit Method (PRL 60)' provided for in
See MoreIMF Comments on Austria’s Fiscal Position
On 12 September 2018 the IMF issued a report following the conclusion of consultations in Austria under Article IV of the IMF’s articles of agreement. Austria’s economic recovery is broad-based with output expanding by 3% in 2017, boosted by
See MoreIMF Report Comments on Russia’s Economy
On 12 September 2018 the IMF published a report following consultations in Russia under Article IV of the IMF’s articles of agreement. The economy is recovering from the recession of 2015–16 owing to an effective policy response combined with
See MoreKazakhstan: Resolution No. 528 of 27 August 2018 publishes for amending APA process
According to Resolution No 528 of 27 August 2018 published on 6 September 2018, the review committee must complete its review within 60 working days of receipt of the application. If the application is approved, the signed contract should be sent to
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