Argentina: Government reforms transfer pricing rules via Decree 1112/2017
The government has issued a Decree No.1112/2017 on December 29, 2017, for enacting and making effective of comprehensive tax reform. It also contains the new rules for transfer pricing. According to the new Law, transactions with parties in low-tax
See MoreWorld Tax Brief: December 2017
Australia Sanctions for tax evasion: On 18 December 2017, the Australian Taxation Office was published a draft law companion guideline (LCG) 2017/D7 on Diverted profits tax (DPT) for public consultation. The draft Guideline addresses Schedule 1
See MoreTransfer Pricing Brief: December 2017
Italy: CbC Reporting requirement-Timing: On December 11, the tax authority issued a Measure no. 288555 extending the due date for filing the CbC report for fiscal year 2016 from 31 December 2017 to 9 February 2018 within 60 days following the
See MoreHong Kong: IRD introduces two tiered profits tax rate
The Inland Revenue (Amendment) (No.7) Bill published on 29 December 2017 proposes to modify Hong Kong’s tax relief for various businesses including reinsurance, captive insurance, aircraft leasing, shipping and corporate treasury centers as these
See MoreCanada: Deadline extends for the access of Voluntary Disclosures program
The Canada Revenue Agency (CRA) has extended the deadline for taxpayers to access the current Voluntary Disclosures Program (VDP). In order for a taxpayer to be eligible for the VDP relief outlined in Information Circular IC00-1R5, unintentional
See MoreUkraine: Parliament adopts the amendment to the Tax Code
On 7 December 2017, the Ukrainian Parliament passed the Law of Ukraine "On Amendments to the Tax Code of Ukraine and Certain Laws of Ukraine on Securing Balance of Budget Revenues in 2018” No. 2245-VIII (“Law”). The law came into force on 1
See MoreUkraine changes in Transfer Pricing Rules from January 1, 2018
On 7 December 2017, the Ukrainian Parliament passed the Law of Ukraine "On Amendments to the Tax Code of Ukraine and Certain Laws of Ukraine on Securing Balance of Budget Revenues in 2018” No. 2245-VIII (“Law”). The law came into force on 1
See MoreItaly: Approval of 2018 Budget Bill including new tax on digital services
The main agenda of this Bill being approved by the Italian Senate was to offset differences on tax on digital services so that it can target large multinational companies like Facebook, Apple and Google providing digital services in Italy. Italy has
See MoreHungary: Deadlines of Country-by-Country reporting and notification requirements
Issues have been generating recently on filling Hungary’s CbC reporting notification on the 17T201T form. A Hungarian resident entity is not required to file the CbC notification requirement until or unless the multi-national group has a
See MoreFrance: US Multinational Groups and the French Country-by-Country reports
The United States hasn’t been yet included in the French Ministerial Order consisting of the list of states for CbCR purposes. Discussions on the authority agreement between France and USA are still going on, which has a bit of suspense running
See MoreItaly: Italian Revenue Agency taking implementing procedures for Country-by-Country Reporting (CbCR)
New law has been introduced by the Italian Revenue Agency for the execution of CbCR concerning the medium of presentation of the reports in Italy which is in the same radar with the OECD recommendations and the EU Directions. It is mainly implied on
See MoreItaly: Provisions for new patent box regime
Italian Government issued an additional Decree to amend the Italian Patent Box regime in order to streamline the existing differences between the Italian rules and the OECD recommendations set forth under Base Erosion and Profit Shifting (BEPS)
See MoreFrance : Temporary Exceptional Surcharge on Large Companies
The French Constitutional Court finalized the “exceptional surcharges” to levy on corporate income of the French largest companies. This exceptional surcharges apply to French companies or branches that are subject to corporate tax, and have
See MoreFinland: Government proposes to align CbC reporting with EU Directive
On 19 December 2017, Bill No. 191/2017 was submitted to the parliament as a proposal to amend section 14 d of the Act on Taxation Procedure which is in line with Council Directive (EU) 2016/881 of 25 May 2016 amending Directive 2011/16/EU. The
See MoreUS Tax Cuts and Jobs Act: Global Intangible Low-Taxed Income
The US Tax Cuts and Jobs Act has introduced various new provisions to counter base erosion and profit shifting by US corporations. These include a base erosion minimum tax, provisions to counter income shifting by intangible property transfers and
See MoreItaly: Tax authority extends the due date for filing the CbC report
On December 11, the tax authority issued a Measure n. 288555 extending the due date for filing the CbC report for fiscal year 2016 from 31 December 2017 to 9 February 2018 within 60 days following the measure’s publication
See MoreUS Tax Cuts and Jobs Act: Income Shifting by Intangible Property Transfers
A U.S. person transferring intangible property to a foreign corporation in a transaction that would otherwise qualify for non-recognition treatment is generally treated as having sold the intangible property in exchange for payments contingent on
See MoreUS Tax Cuts and Jobs Act: Hybrid Transactions and Hybrid Entities
A group could set up an entity that is treated as fiscally transparent for U.S. federal tax purposes but is treated as an entity in the country in which it is resident or subject to tax. Similarly, an instrument may be treated as debt in one country
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