Israel approves three-tiered TP documentation requirements
On 5 July 2021, the Israeli Ministry of Finance announced the approval of proposed amendment to the Transfer Pricing (TP) provisions of the Israeli Income Tax Ordinance (ITO). The amendment proposal introduces the three-tiered TP documentation
See MoreJordan introduces transfer pricing rules for MNE groups
On 7 June 2021, the Hashemite Kingdom of Jordan has published Regulation No. 40 of 2021 in the Official Gazette. The Regulation has introduced transfer pricing rules for multinational entity (MNE) groups with effect from 7 July 2021. The Regulation
See MoreNigeria: FIRS issues a notice to suspend CbC reporting obligations for MNE branches
The Federal Inland Revenue service (FIRS) issued a public notice to suspend Regulation 4 of the “Income Tax (CbC Regulations) Regulations, 2018”. This public notice notifies branches and subsidiaries of Multinational Enterprises (MNEs)
See MoreKenya publishes Finance Bill 2021
On 5 May 2021, the Parliament of Kenya has published the finance bill 2021 providing the following tax measures: Reintroduce the definition of the term ‘‘Control” The definition of the term “control” was deleted with the
See MoreIndonesia: DGT updates XML schema for CbC reporting
On 4 March 2021, the Indonesian Directorate General of Taxation (DGT) updated the XML schema (version 2.0) for country-by-country reports (CbCR). The update includes the new XSD schema; a procedure for creating XML files; and technical guidance
See MoreUK adopts CbC reporting XML schema 2.0
The UK tax authority has updated the country-by-country (CbC) reporting schema to XML 2.0 for submissions to HM Revenue & Customs (HMRC). All CbC reports must use the new 2.0 XML format and submitted to HMRC on or after 1 January 2021. The
See MoreZambia introduces CbC Reporting requirements
On 31 December 2020, Zambia has published The Income Tax (Transfer Pricing) (Amendment) Regulations under Statutory Instrument No. 117 of 2020. The Regulations introduce country-by-country (CbC) reporting requirements, which are effective from 1
See MoreUkraine: MOF approves the procedure for submitting CbC report
On 19 February 2021, the Ukrainian Ministry of Finance (MOF) has issued a press release where they clarify the procedure for submitting Country-by-Country (CbC) report. The Order of the Ministry of Finance No. 764 dated 14 December 2020, which
See MoreFrance: Government publishes a country list with no CbC reporting obligation
On 3 February 2021, Government published a Decree of 3 February 2021, amending the order of July 6, 2017 amended in accordance with II of article 223 quinquies C of the general tax code. The decree comes into force the day after its publication.
See MoreSaudi Arabia: GAZT publishes CbC reporting XML schema version 2.0
Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia has informed that Country-by-Country (CbC) Reporting Schema to V2.0 is being updated. Taxpayers have to submit (CbC) report via AEOI Portal using XML Schema standardized
See MoreAzerbaijan introduces CbC Reporting requirements
Recently, Azerbaijan has introduced Country-by-Country (CbC) reporting requirements and notification requirements for multinational entity groups (MNE groups) headquartered or operating in Azerbaijan. The CbC reporting rules are effective for
See MoreUS and Argentina sign CbC exchange arrangement
On 27 January 2021, US and Argentina have signed a competent authority agreement to exchange country-by-country reports. The purpose of the agreement is to increase international tax transparency and improve access of their respective tax
See MoreAustralia amends the definition of SGE
Australian Taxation Office (ATO) expanded the definition of “significant global entity (SGE)”. The SGE concept determines whether an entity is subject to a number of tax integrity and reporting measures. The SGE concept was introduced by the
See MoreSwitzerland: Review on international financial and tax matters of 2020
Switzerland’s Secretariat for International Finance (SIF) has published its annual review on international financial and tax matters for 2020. With respect to tax-related matters in particular, the review includes the following: Taxing
See MoreRussia declares country names for exchange of CbC Report
On 10 December 2020, Russia has published an order of the Federal Tax Service amending the list of Territories and States with which Russia will automatically exchange Country-by-Country (CbC) reports. The Order entered into force on 21
See MorePeru: SUNAT publishes frequently asked question on CbC Report
On 16 December 2020, the Peruvian tax authorities (SUNAT) has released frequently asked questions (FAQ) in Spanish providing an elaborate description of country-by-country (CbC) reporting, including the format of CbC report, local filing
See MoreCyprus: Tax department extends CbC reporting deadline to 31 January 2021
On 15 December 2020, the Cyprus Tax Department announced an extension to the reporting deadline for country-by-country reports for the year 2019 and notifications for the year 2020. The reporting deadline for submission of country by country
See MoreFinland: Tax authority publishes CbC reporting XML schema version 2.0
On 4 December 2020, the Finnish tax authority has updated its CbC reporting guidance concerning changes in the Country-by-Country (CbC) reporting XML schema to Version 2.0. Version 2.0 (Country-by-Country Reporting XML Schema 2.0) is released by
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