Australia: ATO extends deadline to file CbC reports

29 November, 2018

Significant Global Entities (SGE) that have a Country-by-Country (CbC) reporting obligation for the year ended 31 December 2017 will be aware that the Local file, Master file, and CbC report are due to be lodged by 31 December 2018. However, due

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Egypt: Ministry of Finance publishes new decree 547 outlining new updated TP guidelines

22 November, 2018

On 21 October 2018, Egyptian Ministry of Finance has issued new decree 547 providing the authority for new transfer pricing guidelines to be published. The new guidelines introduced three-tiered level of transfer pricing reports for transparency to

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Uruguay issues guidance of new TP documentation requirements

22 November, 2018

In October 2018, the government of Uruguay issued Decree No. 353/2018 providing regulatory guidance regarding new transfer pricing (TP) documentation requirements. The decree clarifies guidance to implement the transfer pricing documentation

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Bulgaria: MoF proposes new mandatory documentation rule for transfer pricing

21 November, 2018

On 5 November 2018, the Ministry of Finance (MoF) published a draft consultation, proposing new mandatory documents for transfer pricing documentation, and a penalty for failure to comply with up to 1% of the value of undocumented transactions. The

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Latvia: Parliament adopts regulation with new requirements for transfer pricing documentation

18 November, 2018

On 25 October 2018 the Parliament approved amendments to the law ‘On taxes and duties’ which introduce in Latvia the OECD format of the transfer pricing documentation. The law was published on 14 November 2018 as the official Gazette no

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Colombia issues resolution on Local file and master file submission

09 August, 2018

CbC reporting requirement-Timing: On 30 July 2018, Resolution 40 of 26 July 2018 was published in the Official Journal. Accordingly, if a constituent entity is required to submit a specific transfer pricing form (form 120), the CbCR notification

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Poland releases draft law amending transfer pricing rules

31 July, 2018

On 16th July 2018, Poland has released a bill to amend the country's transfer pricing rules in line with the results of the BEPS project and the OECD transfer pricing guidelines 2017 in order to improve the taxation of large multinational companies.

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France: Tax authority publishes transfer pricing guidelines related to BEPS compliance

31 July, 2018

On 18 July 2018, the French tax authorities published instructions regarding Master / Local file in the context of transfer pricing documentation. As per the guidelines, the new documentation requirements apply for fiscal years beginning on or

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Australia: New guidelines for Local and Master file for 2018

15 July, 2018

The Australian Taxation Office (ATO) has published Local file instructions 2018 and Local file/master file 2018 to provide guidance for taxpayers to comply. The local file must be electronically lodged in the approved form (an XML file generated

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Peru: Tax administration issues resolution regarding master file and CbC reporting requirements

12 July, 2018

The tax administration (Superintendencia Nacional de Administración Tributaria, SUNAT) issued Resolution 163-2018/SUNAT (the Resolution) on 29 June 2018 which was published in the Official Gazette. The Resolution sets out the rules for preparing

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Hong Kong: Legislative council passes the transfer pricing legislation

08 July, 2018

On 4 July 2018, the Legislative Council adopted the new transfer pricing regime ((Amendment) (No. 6) Bill 2017 (the “BEPS Bill”)). During the legislative process, some changes were made to the initial bill. Remarkable changes are the possible

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Belgium: Notification for corporate tax compliance

24 June, 2018

As the first half of 2018 almost ends, it is time to look forward to the coming second installment of prepayments. Income tax returns The income tax authorities confirmed the deadline of the filing of corporate income tax returns with a financial

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Latvia: Cabinet Ministers approves a draft bill on Master and Local file

24 May, 2018

Recently, the Latvia Cabinet of Ministers has approved a draft law for the introduction of Master and Local file requirements in line with BEPS Action 13. Under the law, taxpayers resident in Latvia are required to submit Master file within 12

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Kazakhstan: State Revenue Authority announces introduction of TP documentation

02 May, 2018

The State Revenue Authority declared on April 25, 2018, about the introduction of a three-level method to transfer pricing documentation. The Kazakh President, signed a series of laws, including Law 122-VI on 25 December 2017 regarding transfer

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India: The deadline for multinationals to submit a master file and CbC report is 31 March

15 March, 2018

The due date for multinationals in India to furnish a country-by-country (CbC) report and masterfile for the accounting year 2016-17 is 31 March 2018. The master file must be submitted on Form 3CEAA. Part A of the form is required for all

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India: CbC reporting changes made in Finance Bill 2018 as passed by the Lok Sabha

15 March, 2018

On 14 March 2018, the lower house of parliament (Lok Sabha) has approved the Finance Bill 2018 with modifications. One of the main changes includes by the bill is changes to the country-by-country (CbC) reporting and Master file requirements. The

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Finland: Tax administration publishes new guidance on TP documentation

11 February, 2018

On 29 January 2018, the tax administration issued the new guidance No.A129/200/2017 on transfer pricing documentation, which replaces the previous guidance of 2007. The documentation requirement is divided into a master file and a local file. The

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Taiwan: MoF announces Safe harbor exemption

29 January, 2018

Taiwan's Ministry of Finance (MoF) announced a “safe harbor” exemption with respect to Master file and country-by-country (CbC) reporting On 11th December 2017. Transfer pricing guidance issued in November 2017 (and known in English as

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