Serbia publishes rulebook on updating transfer pricing rules
On 1 October 2021, the Serbian Ministry of Finance has published the updated rulebook on transfer pricing. The updated rulebook includes the more detailed guidance regarding CbC report including the conditions, content, and manner of submitting
See MoreMalaysia: IRBM releases updated FAQs providing new CbCR submission requirement
On 13 September 2021, the Inland Revenue Board of Malaysia (IRBM) has published the updated “frequently asked questions on tax matters during the national recovery plan”. Accordingly, companies in Malaysia responsible for filing the CbCR report
See MoreNigeria: FIRS suspends CbC report local filing for non-parent entities
In September 2013, the Organization for Economic Co-operation and Development (OECD) and G20 countries, working together on an equal footing, adopted an ambitious and comprehensive 15-point Action Plan to address BEPS. The Action Plan aims to
See MoreDominican Republic: DGII invites for public comments regarding CbC reporting requirements
Recently, the Directorate General of Internal Revenue (DGII) declared a public consultation on a draft general standard regarding country-by-country (CbC) reporting. The DGII invited for public comments up to 7 September 2021. The CbC report
See MoreLuxembourg updates electronic exchange and frequently asked questions of CbC report
On 20 August 2021, Luxembourg has announced that the section "Electronic exchange - country by country (CbC) reporting" as well as the frequently asked questions relating to the CbC declaration have been updated. Please note that the frequently
See MoreColombia issues Resolution on transfer pricing return and CbC notifications
On 11 August 2021, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales-DIAN) has issued Resolution No. 000072 setting out the procedure of the submission of the transfer pricing return and CbC notification for the tax
See MoreIsrael 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
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