Colombia: DIAN clarifies TP filing obligations under BEPS Action 13
On 3 May 2017, the Colombian Tax Authority (DIAN) clarified the fiscal years for which the new transfer pricing obligations established in Article 108 of Law 1819 of 2016 will apply. According to Law 1819, taxpayers have to file a local file, master
See MoreRussia: Publishes the draft law on CbC reporting requirements for multinationals corporate groups
The Russian government on 6 March 2017, published an amended draft law providing for new provisions on the international automatic exchange of financial accounting information for the Russian fiscal regulation and for setting new standards for the
See MoreAustralia publishes CbC reporting, Local and Master files detailed design
The Australian Taxation Office (ATO) has published a Local file / Master file detailed design to serve as guidance for taxpayers regarding the practicalities in completing country-by-country (CbC) reporting by significant global entities. ATO has
See MoreMexico publishes final report for country-by-country reporting
Mexico’s Taxpayer Office published a final report regarding master file, local file and country-by-country (CbC) report under Article 76-A of the Income Tax Law on April 3, 2017. These documentation requirements became effective on January 1,
See MoreUK: Amendments to CbC reporting 2017
The United Kingdom was one of the first countries to formally commit to introducing CbC reporting and the detailed implementation was given effect through the 2016 Regulations. Since the UK introduced these regulations in February 2016, the
See MoreSweden approves the new legislation on transfer pricing documentation and CbC reporting
Sweden's parliament on 1 March 2017, adopted the government’s proposal on transfer pricing documentation and country-by-country reporting. The adoption amounts to the ratification of OECD’s guidelines for transfer pricing documentation and
See MoreColombia: Tax reform 2016 and Transfer Pricing Updates
In accordance with law 1819 of 2016, adopting the structural tax reform bill approved on 23 December 2016, introduces the following main changes to the transfer pricing regime. According to article 260-3 of the Tax Code (TC), as amended by the tax
See MoreKorea- proposed changes to the country-by-country reporting requirements
The Ministry of Strategy and Finance of South Korea published a proposal for detailed procedures of the country -by country reporting requirements on 28 December 2016. The proposal requires the provision of a full report on cross-border transactions
See MoreKorea-Tax reform bill of 2017 enacted
Korea enacted the tax reform bill of 2017 on 20 December 2016 which was approved by the National Assembly on 2 December 2016. According to the Tax Reform of 2017 domestic merged brother-sister companies would be considered as tax free if and only
See MoreBelgium issues TP documentation forms and instructions
During June 2016, Belgium has introduced mandatory transfer pricing documentation and country-by-country (CbC) reporting requirements in accordance with Base Erosion and Profit Shifting (BEPS) Action 13 of the Organisation for Economic Co-operation
See MoreColombia: Tax reform bill 2016
The comprehensive tax reform bill 2016 recently submitted by the government of Colombia to the Congress with the following corporate income tax issues: Rates: The bill proposes to unify the income tax and the Fairness Tax into a single income tax
See MoreMexico: Tax Authorities issues proposed regulations
Mexican Tax Authorities issued proposed regulations regarding the “additional information” that could be requested as part of the new transfer pricing obligations, which require Mexican taxpayers to submit a master file, local file and
See MoreRussia: New version of draft law on BEPS Action 13 implementation issued
The Finance Ministry has issued a new version of the draft law on 6th September 2016 regarding BEPS Action 13 implementation. The draft law proposes the following topics: BEPS related compliance: Documentation requirement: Master file: As per the
See MoreUruguay-Bill on adoption of CbC reporting, Master file documentation and the availability of bilateral and multilateral APAs
The Uruguay Government has submitted to Congress a tax bill including adoption of the OECD’s recommendations for Country-by-Country (CbC) reporting following the scope of information to be provided under the Base Erosion and Profit Shifting (BEPS)
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”
See MoreAustria: Publishes government bill of new Transfer Pricing Documentation Law
Finance (MoF) published the government bill of the European Union (EU) Tax Amendment Act 2016, including among other provisions, the new Austrian Transfer Pricing Documentation Law (TPDL). This follows the publication of the draft TPDL on 9 May 2016
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