Taiwan: MoF announces Safe harbor exemption
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
See MoreDenmark introduces new deadline for transfer pricing documentation
On 7 December 2017 the Danish Parliament passed a new law (No. L 13) launching a deadline for preparing and submitting the transfer pricing documentation. The most important changes are: The new law requires to prepare the transfer pricing
See MoreKazakhstan: Tax Law Reforms for the year 2018
The Kazakh President, signed a series of laws on 25 December 2017 regarding taxes and other mandatory payments, introduction of tax code, law on amendments to other Acts etc. Most provisions of the new tax code and the tax amendments effects from 1
See MoreRussia publishes final law on automatic exchange of tax information and documentation requirements
Recently, the Federal Law No. 340-FZ of 27 November 2017, amending the Tax Code in relation to the implementation of the international automatic exchange of financial accounting information and transfer pricing (TP) documentation of multinational
See MorePakistan: FBR publishes rules for documentation and CbC reporting requirements
On 16 November 2017, the Federal Board of Revenue (FBR) in Pakistan has published SRO 1191(1)/2017, which includes chapter VIA to the Income Tax Rules of 2002. The new Chapter (VIA) identifies the reporting entities, clarifies the reporting
See MoreTaiwan: 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 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 MoreIndia: CBDT publishes rules for CbC reporting and Master File rule
On 1 November 2017, the Central Board of Direct Taxes (CBDT) has notified rules in respect of Country-by-Country reporting and furnishing of Master File. The significant features of the Country-By-Country Report and Master File rules are: The
See MoreIndia: CBDT publishes the Final Rules for CbC reporting and the furnishing of the master file
On 31 October 2017, the Central Board of Direct Taxes (CBDT) published the Final Rules for country by country (CbC) reporting and the furnishing of the master file. The Final Rule contain a few administrative changes and clarifications. However, the
See MoreSouth Africa: SARS publishes public notice on the submission of CbC report
On 13 October 2017, the South African Revenue Service published the public notice on the submission of Country-by-Country (CbC) report, Master file, and Local file information returns under the external business requirements specification (BRS). A
See MoreColombia publishes newly proposed TP regulations
Tax Authorities of Colombia (DIAN) published a proposed transfer pricing (TP) regulations to execute the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Action 13 and to establish the
See MoreIndia: CBDT releases CbC reporting and Master file documentation rules for public comment
The Central Board of Direct Taxes (CBDT) published a draft guideline for framing Rules in respect of Country-by-Country reporting and furnishing of master file on 6 October 2017. The comments and suggestions on the draft rules can be submitted by 16
See MoreColombia issues draft decree on transfer pricing regulations
The Ministry of Finance and Public Credit of Colombia issued a draft decree 1625 of 2016 concerning transfer pricing documentation for public consultation on 11 August 2017. The major issues in the proposed decree are business restructuring rules,
See MoreHungary: Draft law published on amended transfer pricing documentation requirements
The Hungarian government has finalized the draft legislation concerning amended transfer pricing documentation requirements which will be presented to the parliament in the autumn of 2017. Hungary is expected to introduce rules regarding Master file
See MoreIndia introduces CbC reporting requirements
India has included a country-by-country (CbC) reporting requirement in section 286 of the Indian Income-tax Act, 1961, with effect from the financial year 2016-2017. The requirements are principally in line with BEPS Action 13. The first round of
See MorePakistan: Proposes documentation and CbC reporting requirements
On June 5, 2017, Pakistan's Federal Board of Revenue has presented a notification (Notification SRO 421 (I) / 2017) regarding Documentation and country-by-country reporting requirements in respect of transfer pricing. The proposed requirements are
See MoreTurkey: Council of Minister proposes transfer pricing provisions
A draft Communique regarding transfer pricing has been published in Turkey. It generally represents measures of the OECD’s base erosion and profit shifting (BEPS) Action 13 on country-by-country reporting and transfer pricing documentation. The
See MoreBelgium: New CbC reporting forms and guidelines
On 19 May 2017, the Belgian Federal Public Service for Finance issued new country-by-country (CbC), local file and master file forms along with guidelines to file CbC reports under BEPS Action 13. The report submission deadline was 31 December 2016,
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