Taiwan: MoF announces changes to the transfer pricing documentation rules
The Ministry of Finance (MoF) published the amendment of Transfer Pricing Audit Rules on 13th November 2017. The rules established three-tiered transfer pricing documentation in accordance with the OECD under the base erosion and profit shifting
See MoreRomania: Guidance published on form for country-by-country reporting
On 14 November 2017, the tax administration published guidance Order no. 3049/2017 concerning the form to be used for filing country-by-country (CbC) reports. According to Order no. 3049/2017, the “country-by-country reporting” form should be
See MoreSweden: Income of pension funds to be included in the CbC reporting
The Swedish Tax Agency on 8 November 2017, has published a clarification (No. 202 439672-17/111) on any pension funds derived by life insurance companies, foreign occupational retirement institutions and pension funds pay are to be regarded as
See MoreSaudi Arabia: Circular issued on implementation of recent tax law amendments relating to tax appeal procedures
General Authority for Zakat and Taxes (GAZT) of Saudi Arabia has clarified in its Circular No. 7258/16/1439 of 14 November 2017 that the appeal procedure under Articles 66 and 67 of the Income Tax Act is applicable until new Appeals Committees are
See MoreSingapore: OECD concludes tax incentives meet international BEPS standards
Singapore is an "associated" jurisdiction under the BEPS (Base Erosion and Profit Shifting) project. Singapore’s available tax incentives were reviewed by the Forum on Harmful Tax Practices and found to be “not harmful” under the peer review
See MoreMexico: Congress approves budget for 2018
Mexico’s Congress gave final approval to the federal budget for 2018 on 15th November
See MoreUS: IRS releases practice units on APAs for tangible goods transactions
On November 6, 2017, the Internal Revenue Service (IRS) released two new international Practice Units (IPUs) in connection with Advance Pricing Agreements (APAs) for inbound and outbound tangible goods transactions. The IPUs provide a summary of the
See MoreUkraine clarifies classification of transactions with a non-resident legal entity
On October 4, 2017, the State Fiscal Service (SFS) published Letter No. 1945/6 / 99-99-15-02-02-15 / IPK of September 13, 2017, which specifies the classification of transactions with a non-resident legal entity for the purpose of transfer
See MoreSingapore: Tax exemptions for corporate re-domiciliations
On 11 October 2017, Singapore's Accounting & Corporate Regulatory Authority (ACRA) has immediately adopted the Companies (Transfer of Registration) Regulations 201, which allows eligible foreign companies to relocate their registered offices to
See MoreRomania: Ordinance amending the Tax Code published
In the Official Gazette no. 885 of 10 November 2017, Emergency Ordinance no. 79 concerning the modification and completion of Law no. 227/2015 regarding the Tax Code has been published by the Romanian Government. According to the new rule a taxpayer
See MoreQatar joins BEPS inclusive framework and signs BEPS Multilateral Instrument
The Organization for Economic Co-operation and Development (OECD) made an announcement on November 14, 2017, that Qatar joined the Base Erosion and Profit Shifting (BEPS) inclusive Framework. The BEPS inclusive framework is a group of countries that
See MoreColombia: New guidance for CbC reporting
In accordance with the amendments introduced by Article 108 of Law 1819 of 2016 modified article 260-5 of the Tax Code, the Colombian national tax authority (DIAN) announced that the new conditions must be fulfilled by taxpayers who are subject to
See MoreHungary: New transfer pricing Decree on Transfer Pricing Documentation rules
On 18 October 2017, the Hungarian Ministry of National Economy (NGM) issued a decree on new Transfer Pricing Documentation rules. According to the provisions of the Decree, a group is required to prepare a master file and a local file from fiscal
See MoreColombia: New interest rate for late payment of tax
On 27 October 2017, according to Resolution 1447, the Colombian Tax Authority (DIAN) has announced that the yearly late tax payments interest rate is reduced to 29.44% from 29.73% for November 2017 set by the Financial Superintendence of
See MoreBelgium: Government approves draft law on corporate tax reform with fully participation exemption
On 27 October 2017, according to a press release, on the proposal of the Minister of Finance, the government has approved the corporate tax reform. The corporate tax reform process would take place in two phases, 2018 and 2020. Belgium will grant
See MoreHungary: Proposal of increasing VAT registration thresholds
Hungary is working out a plot to strengthen its VAT registration threshold from HUF8 million to a hefty HUF12 million. This will be effective from 1 January 2019. The threshold will not be applicable for non-resident businesses, which must be
See MoreGermany: Capital gains 100% tax-exempt for foreign corporate shareholders
On 25 October 2017, the German Federal Tax Court (decision dated 31 May 2017) ruled in favor of foreign shareholders selling shares in a German corporation. Capital gains realized upon sale of shares in a German resident corporation by non-resident
See MoreBahrain: Cabinet approves draft law regarding excise tax
The Cabinet approved a draft-law on ratifying the Gulf Cooperation Council (GCC) unified selective excise tax on unhealthy drinks on 16th October 2017. The Cabinet has endorsed an excise tax bill that would impose a 100% tax on tobacco products,
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