US and Indonesia sign MOU on the exchange of CbC reports
On April 26, 2018, the Internal Revenue Service issued a Memorandum of Understanding (MOU) between the Competent Authorities of the United States (US) and Indonesia, which includes an announcement of the temporary suspension of Indonesia's secondary
See MoreAustralia: ATO announces CbC reporting deadline for local file
The Australian Taxation Office (ATO) has released its final draft of the 2018 Message Structure Table (MST) and XML Schema for the Australian Local File (ALF) for tax year 2018. This will represent the second ALF that most taxpayers will be required
See MoreKazakhstan: State Revenue Authority announces introduction of TP documentation
The State Revenue Authority declared on April 25, 2018, about the introduction of a three-level method to transfer pricing documentation. The Kazakh President, signed a series of laws, including Law 122-VI on 25 December 2017 regarding transfer
See MoreIndonesia launches electronic system for CbC report submission
On 13 April 2018, Directorate General of Taxation of Indonesia has declared the launch of the electronic submission system for Country-by-Country (CbC) reports via the DJP Online Portal. The system provides a step-by-step guideline for the
See MoreUS: IRS publishes a notice concerning CbC reporting requirements of certain U.S. MNE groups
On 30 March 2018, IRS released an advance copy of Notice 2018-31 concerning national security considerations with respect to country-by-country (CbC) reporting. In consideration of the national security interests of the United States, the notice
See MoreIndia: President approves Finance Act 2018
On 29 March 2018, the Finance Bill 2018 received the approval of the president and now is enacted law, following some changes made by the lower house of parliament on 15 March 2018. This law would apply with effect from 1 April 2018. The main tax
See MoreIndia publishes clarification regarding requirement for furnishing CbC report
On 23 March 2018, the Government of India published clarification regarding requirement for furnishing of Country-by Country Report under Section 286(4) of Income Tax Act, 1961. The government also confirmed that where a non-parent constituent
See MoreIndonesia: New guidance on CbC reporting
On 26 March 2018, the tax authority of Indonesia published an updated guidance on Country-by-Country (CbC) reporting. The guidance includes: The general CbC reporting requirements applicable for MNE groups with consolidated gross revenue
See MoreRussia approves bilateral exchange agreements for CbC reports
The Government of the Russian Federation has published Decree No. 184 of 21 February 2018, which amends Decree No. 805 of 14 August 2014 on the conclusion of agreements for the exchange of information in tax matters. The changes include the
See MoreIndia: CbC reporting changes made in Finance Bill 2018 as passed by the Lok Sabha
On 14 March 2018, the lower house of parliament (Lok Sabha) has approved the Finance Bill 2018 with modifications. One of the main changes includes by the bill is changes to the country-by-country (CbC) reporting and Master file requirements. The
See MoreHong Kong introduces CbC reporting portal
On 5 March 2018, Hong Kong government announced that it has launched its country-by-country reporting portal. Hong Kong Ultimate Parent Entities of Reportable Groups (HK UPEs) can now file CbC Returns for accounting periods beginning between 1
See MoreSingapore: Published Country-by-Country Reporting regulations
The Government of Singapore published Country-by-Country Reporting in the Singapore Government Gazette the “Income Tax Regulations 2018” on 5 February under the Income Tax Act (ITA). Country-by-Country reporting application and
See MorePakistan issues more draft amendments to CbC reporting requirements
On 9 February 2018, the Federal Board of Revenue (FBR) in Pakistan has published SRO no. 144(I)/2018, which provides more amendments to draft rules that establish transfer pricing documentation and country-by-country reporting rules for large
See MoreIndia: Budget 2018 proposes rules for implementation CbC reporting requirements
On 1 February 2018, the Finance Minister presented the Union Budget 2018. The budget includes proposals to clarify rules for implementation of the country-by-country (CbC) reporting requirements. Consequently, the due date for submits the CbC
See MoreCosta Rica: Tax administration Gazettes CbC reporting resolution
On 2 February 2018, Costa Rica published the Resolution no.DGT-R-001-2018. Resolution No.DGT-R-001-2018 requires multinationals to submit a CbC report in accordance with the OECD's recommendations for the erosion and profit shifting base (BEPS)
See MorePakistan: FBR publishes amendments to CbC reporting requirements
On 31 January 2018, the Federal Board of Revenue (FBR) in Pakistan has published SRO no. 99(I)/2018, which provides amendments to draft rules that establish transfer pricing documentation and country-by-country (CbC) reporting requirements for large
See MoreTaiwan: 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 MoreIndonesia: CbC Reporting implementing regulations
The Director General of Taxation (the DGT) of Indonesia issued DGT Regulation 29/PJ/2017 (PER-29) concerning implementing regulations on Country-by-Country (CbC) Reporting requirements, effective as of 29 December 2017. PER-29 provides some clarity
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