Australia: ATO extends deadline to file CbC reports
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
See MoreEgypt: Ministry of Finance publishes new decree 547 outlining new updated TP guidelines
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
See MoreUruguay issues guidance of new TP documentation requirements
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
See MorePeru: SUNAT extends deadline for submission of CbC report to March 2019
On 11 November 2018, Peruvian tax authorities (SUNAT) published Ruling No. 264-2018 SUNAT which extended the due date for submitting CbC report from November 2018 to March 2019 for fiscal year 2017. The extension applies to Peruvian taxpayers who
See MoreArgentina: General Resolution 4332/2018 publishes regarding CbC reporting requirements
The Federal Administration of Public Revenues (AFIP) has published General Resolution 4332 of 8 November 2018, which includes several amendments to General Resolution 4130 regarding Country-by-Country (CbC) reporting. It enters into force from
See MoreArgentina: AFIP publishes information regarding CbC reporting
On October 24, 2018, the tax authority (AFIP) published information regarding Country-by-Country (CbC) reporting in their website. Two information regimes are implemented in order to combat tax evasion and avoidance and the transfer of benefits to
See MoreOECD: Tax Talk discusses progress on key tax issues
An OECD Tax Talk on 16 October 2018 discussed the latest developments on tax issues. Tax Challenges of Digitalisation In March 2018 the Task Force on the Digital Economy (TFDE) sent an interim report to the G20 on the tax challenges of
See MoreQatar: MoF implements new CbC requirements through Decision No. 21 of 2018
The Ministry of Finance published a Decision No. 21 of 2018 on September 9, 2018 in the Official Gazette. This Decision implements new Country-by-Country (CbC) reporting requirement. It is effective from September 10, 2018. A CbC report contains
See MoreNigeria: FIRS publishes a public notice regarding CbC Regulations
The Federal Inland Revenue Service (FIRS) issued a public notice on September 17, 2018. This notice provides alert that income tax country-by-country (CbC) reporting regulations S.I. no. 6, 2018 entered into force with effective from January 1, 2018
See MoreSingapore: IRAS publishes e-tax guide on country-by-country reporting
On 7 August 2018, the Inland Revenue Authority of Singapore (IRAS) published the third edition of its e-Tax Guide concerning country-by-country reporting. The purpose of the guide is to provide information to the taxpayers regarding the obligation
See MoreColombia issues resolution on Local file and master file submission
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
See MoreFrance: Tax authority publishes transfer pricing guidelines related to BEPS compliance
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
See MoreUS: IRS updates information regarding country-by-country (CbC) reporting
On 25 July 2018, Internal Revenue Service (IRS) updated the information concerning country-by-country (CbC) reporting in the United States. This includes an updated jurisdiction status table showing recently signed competent authority arrangements
See MoreOECD: Inclusive Framework Issues Progress Report
The OECD’s Inclusive Framework on base erosion and profit shifting (BEPS) has issued a progress report of its activities in the year to June 2018. The report indicates that significant developments have taken place in BEPS implementation during
See MoreIreland updates CbC Report submission guideline
On 19 July 2018, Irish revenue authority published a Tax and Duty Manual Part 38-03-21 to confirm that requests for technical support in relation to Country-by-Country Reporting must be submitted to Revenue using MyEnquiries through the Revenue
See MoreAustria: Parliament approves Exchange of CbC Reports and Financial Account Information
On 11 July 2018, the Federal Council (upper house of parliament) of Austria adopted two declarations as approved by the National Council (lower house) on 4 July 2018. The two declarations are relating to the effective date of the multilateral
See MoreNew Zealand’s taxation act regarding Neutralising Base Erosion and Profit Shifting receives royal assent
New Zealand's Taxation (Neutralising Base Erosion and Profit Shifting) Act received royal assent on 27 June 2018. The main measures of the Act are summarized as follows: CbC reporting requirement: According to the published guidance on
See MoreU.S. and Indonesia sign an agreement on the exchange of CbC reports
According to an IRS announcement on its website, the competent authorities of the U.S. and Indonesia have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of
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