India: 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 MoreArgentina: General Resolution 4130-E publishes in Official Gazette
The Federal Tax Administration (FTA), on September 20, 2017, published the General Resolution 4130-E in the Official Gazette. It establishes the country-by-country (CbC) guiding framework in Argentina and is applicable to ultimate parent entities of
See MoreNetherlands: Tax plan for 2018
The Dutch government has presented the tax plan for 2018 on 19th September 2017. If adopted, these proposals will be entered into force on 1st January 2018. 2018 tax plan contains various other amendments on a variety of topic and these are given
See MoreUS: IRS releases final versions of CbC form and instructions
The Internal Revenue Service has recently released final versions of the form and instructions for filing country-by-country (CbC) reports. Parent entities of U.S. multinational enterprise (MNE) groups with $850 million or more of revenue in a
See MoreRomania: Country-by country reporting requirements implemented
The Romanian Government passed Emergency Ordinance no. 42/2017 on 9 June 2017 to implement country-by-country (CbC) reporting requirements in Romania, transposing the provisions of Directive (EU) 2016/881 dated 25 May 2016 into the national
See MoreNetherlands: Parliament adopted new Bill on CbC reporting requirement
The Dutch lower house of Parliament adopted the Bill No.34651 to implement country-by-country (CbC) reporting on April 18, 2017. The bill allowed a group entity to serve as the reporting entity and a designated Dutch group entity to file an
See MoreCzech Republic: Proposed requirements for preparing CbC report
On 2nd of August 2016, the Finance Ministry published a public consultation on a bill. This would implement the country-by-country (CbC) reporting requirements in EU Directive 2016/881 on exchange of CbC reports among EU member states. In
See MorePoland: President signs new legislation on CbC reporting requirement
The new legislation regarding the exchange of tax information with other countries was signed by the President on 20 March 2017. The Law provides information on obligations of financial institutions and the automatic exchange of country-by-country
See MoreIceland updates regulation on CbC reporting
The Ministry of Finance and Economic Affairs issued Regulation No. 245/2017 amending Regulation No. 1166/2016 regarding country-by-country (CbC) reporting on 24 March 2017. The amendment aligns the wording of article 4 of the model provision related
See MoreNetherlands amendments to bill on country-by-country reporting
The State Secretary for Finance has submitted an amended bill to the lower house of the parliament regarding country-by-country reporting on 21 March 2017. The bill implementing Council Directive (EU) 2016/881 of 25 May 2016 amending Directive
See MoreItaly-Ministerial Decree implementing Country-by-Country Reporting issued
The Italian Ministry of Finance issued a Decree on 8 March 2017 providing detailed information regarding the application of CbC reporting rules. The Decree is in accordance with an EU Directive of 25 May 2016 requiring all EU Member States to
See MoreBrazil: Regulation on CbC reporting
Normative Instruction 1,681/2016 was issued in the Official Gazette on 29 December 2016 regarding annual country-by-country (CbC) reporting. According to Normative Instruction 1,681/2016: Legal entities resident in Brazil are obliged to
See MorePoland: Amendments regarding TP documentation come into effect
Corporate Income Tax Law amendments gazetted in the Official Journal 1932/2015 regarding transfer pricing (TP) reporting obligations in line with Action 13 of the OECD Base Erosion and Profit Shifting (BEPS) project came into effect on 1 January
See MoreIceland: Ministry of Finance publishes regulation on country-by-country reporting
The Ministry of Finance and the Economy published Regulation No. 1166/2016 on the submission of country-by-country reports (CbC) on 22 December 2016. Under the article 3 of the regulation, Iceland’s parent company resident need to submit a CbC
See MoreChile: CbC reporting implemented
The Tax Authority of Chile published Resolution 126 on 27th December 2016 to implement country-by-country (CbC) reporting. It requires specific taxpayers to submit an annual report to the tax authority disclosing the level of income, profit or
See MoreCzech Republic: Bill introducing CbC reporting submitted to parliament
The government of Czech Republic has submitted a bill on 22nd December 2016 to the parliament, which, if approved, would announce changes to the Law on International Cooperation in the Administration of Taxes. It would implement the provisions
See MoreSingapore- Voluntary filing of CbC Reports for Singaporean tax resident MNE groups for fiscal year 2016
The Inland Revenue Authority of Singapore (IRAS) announced on 19 December 2016 that the voluntary filings for Singaporean multinational enterprise groups for financial year 2016 will be allowed and this follows the e-tax guide of the
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
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