Canada: Country-by-country reporting legislation introduced
Following on the Organization for Economic Cooperation and Development’s (OECD) Base Erosion and Profit Sharing (BEPS) initiative, the Finance Department has released draft legislative proposals on 29th July 2016 that would implement certain
See MoreGreece: Filing of amending tax return after expiry of statute of limitation period
The Public Revenue Authority (PRA) has released Circular POL 1114 on 22nd July 2016 to provide clarification regarding the filing of an amending tax return following the expiry of the statute of limitation period. The Circular says that Opinion No.
See MoreWTO backs Argentina’s anti-avoidance tax measures
The Appellate Body of the World Trade Organization (WTO) provided its report on 14 April 2016, regarding "Argentina – Measures relating to trade in goods and services" case brought by Panama. In the case concerned, and in relation to Argentina's
See MoreWorld Tax Brief: July 2016
Argentina Dividend: In Argentina, Law 27,260, the amendment to the Income Tax Law (LIG) was publishes in the Official Gazette. According to the amendment Law 27,260 abolished the 10% withholding tax established by article 90 LIG which was applied
See MoreUK: Interest rates for late payments reduced according to base rate of Central Bank
On 4 August 2016, the Bank of England reduced the base rate to 0.25%. As a result, on 5 August 2016, HMRC announced that interest rates for late payment will be reduced with effect on: 15 August 2016 for quarterly installment payments; and 23
See MoreTransfer Pricing Brief: July 2016
Austria: BEPS Related Compliance Master file information: Austria has introduced a requirement for a master file for constituent entities resident in Austria if their turnover in the previous two fiscal years exceeded €50 million in each year.
See MoreIreland published new APA guidelines
The Irish Revenue published bilateral advance pricing agreement guidelines on June 23 relating to the operation of Ireland’s APA program, which is effective for applications received on or after July 1, 2016. The guidance outlines the framework of
See MoreMexico: Government passes new transfer pricing rules for APA
The Mexican government recently passed a new regulation to permitting the Mexican Tax Authorities to perform on-site visits to carry out their own functional analysis as a part of the Advanced Pricing Agreement (APA) process. Rule 2.12.8 published
See MoreRussia: Notification of tax authorities concerning CFCs
The Finance Ministry (MoF) has issued a Letter No. 03-01-23/30779 on 27th May 2016 for clarifying the responsibility of taxpayers to notify the tax authorities about CFCs. On the basis of section 3.1 of article 23 of the Tax Code, taxpayers have to
See MoreSlovak Republic: MoF publishes a guideline regarding TP documentation
The principle of transfer pricing is the pricing of goods, services and so on in related party transactions surrounded by multinational enterprises to fulfill the conditions for a self-governing business relationship or to meet the arm’s length
See MoreGreece: Bill regarding transfer pricing provisions enacted
The Greek Parliament has approved a bill of the Finance Ministry on 27th July 2016 introducing significant changes regarding the transfer pricing documentation provisions. The bill, inter alia, amended various provisions of the Greek Tax Procedure
See MoreOECD: Addressing BEPS involving interest in the banking and insurance sectors
On 28 July 2016 the OECD issued a discussion draft outlining approaches to combating base erosion and profit shifting (BEPS) involving interest in the banking and insurance sectors. This is part of further work following the final report on BEPS
See MoreUK: Statistics for Creative Industries Tax Relief
On 20 July 2016 the UK published updated statistics on claims for creative industry tax relief. The statistics include data for the film tax relief, high end television tax relief, animation tax relief and video games tax relief for periods up to
See MoreOECD: Report to G20 finance ministers
On 26 July 2016 the OECD published on its website the report prepared for the meeting of the G20 finance ministers held on 23 and 24 July 2016. The report contains updates on progress on the implementation of the recommendations of the reports on
See MorePlatform for Collaboration on Tax: Report to G20 on capacity building
On 25 July 2016 the Platform for Collaboration on Tax made available a report on enhancing the effectiveness of external support in building tax capacity in developing countries. The report was written for the meeting of the G20 finance ministers
See MoreChina issued new rules on TP documentation requirement
China issued Bulletin 42 to introduce a requirement for a master file for MNC group resident in China if their annual inter-company transaction amount exceeds RMB 1 billion. The master file requirement is effective from fiscal year 2016. A master
See MoreBelgium issued new rules on CbC reporting and TP documentation requirement
Belgium issued regulation to introduce a requirement for a master file and a local file for MNC group resident in Belgium if it satisfies one of the three thresholds like a sum of operational and financial income of €50 million; or a balance
See MoreKorea: Revised draft legislation on transfer pricing and country-by-country reporting
The South Korean Ministry of Strategy and Finance has recently released a draft legislation which would amend the existing provisions of Article 11 of the Korean Law which is known as the “Law for the Coordination of International Tax Affairs”
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