Argentina: 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 MoreMalaysia: IRBM publishes sample notification letters for CbC reporting
The Inland Revenue Board of Malaysia (IBRM) has recently published two different sample notification letters for entities subject to the country-by-country (CbC) reporting notification requirement. Two separate sample notifications letters have been
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 MoreLithuania: Approves country-by-country reporting rules
On 31 May 2017, the Lithuanian Tax Administrator has approved (Order No VA–47) the reporting rules for the multinational enterprise also known as country by country (CbC) reporting rules. These rules came into force as of 5 June 2017. Under this
See MoreColombia issues draft decree on transfer pricing regulations
The Ministry of Finance and Public Credit of Colombia issued a draft decree 1625 of 2016 concerning transfer pricing documentation for public consultation on 11 August 2017. The major issues in the proposed decree are business restructuring rules,
See MoreBelgian tax authority declared CbC reporting notification deadline
According to Belgian law enterprises that meet the country-by-country (CbC) thresholds requirement will have to provide the first CbC reporting notifications to the tax authorities by 30 September 2017. For this first year’s notification, an
See MoreSlovenia publishes detailed guidelines on CbC reporting
The Ministry of Finance (MoF) on 26 July 2017, issued detailed guidelines for Country-by-Country (CbC) reporting. The guidelines also include the form and instructions for submitting the CbC reporting notification and require the following essential
See MoreUK: HMRC confirms CbC reporting format for multinationals
On 15 August 2017, HM Revenue & Customs (HMRC) released guidance confirming the format and method of filing country-by-country (CbC) reports that are due in the UK. The UK follows the CbC reporting requirements of the Organisation for Economic
See MoreBulgaria: CbC reporting legislation adopted through significant changes to TSSPC
A Law on Amendment and Supplementation of the Tax and Social Security Procedure Code (TSSPC) was published in issue 63/04.08.2017 of the State Gazette. The country-by-country reporting (“CbCR”) legislation introduced by the Directive is
See MoreBelgium adopts draft bill to implement EU directives on automatic exchange of information
The Belgian parliament adopted the draft bill to implement the EU Directive 2014/107/EU for mandatory automatic exchange of information, on 20 July 2017 and the bill was published in the Belgian Official Gazette, on 11 August 2017. The Bill
See MoreLatvia: State Revenue Service announces CbC reporting regulations
The Latvian State Revenue Service (SRS) on 08 August 2017 announced the Country-by-Country (CbC) reporting regulations, which were approved by the Latvian Cabinet in July following an amendment to the Law on Taxes and Duties to require CbC reports.
See MorePakistan implements documentation and CbC reporting requirements
In Pakistan until 2016, no transfer pricing documentation was required under the Income Tax Ordinance (ITO). However, with effect from 1 July 2016, the Government has approved the new legislation to effectively implement the Country-by-Country
See MoreIndia: Multilateral Competent Authority Agreement on Exchange of CbC reports enters into force
The Ministry of Finance on 28 July 2017 has issued a Notification (No. 75/2017), which announces that the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country (CbC) Reports entered into force for India on 12 May 2016 and
See MoreUS: IRS now accepting CbC reports
On 11 August 2017 the US IRS in its latest bulletin of news and information on country by country (CbC) reporting advised that parent entities of U.S. multinational enterprise (MNE) groups with $850 million or more of revenues in a previous annual
See MoreGreece: Law 4484/2017 regarding TP documentation requirements publishes
The Law 4484/2017 entitled "Adaptation of Greek Legislation to the provisions of Directive (EU) 2016/881 and other provisions" was published in the Government Gazette on August 1, 2017. It harmonizes Greek legislation with the provisions of Council
See MoreBrazil publishes amended regulation on CbC reporting
Normative Instruction 1,722/2017 published in Brazil’s Official Gazette on 17th July 2017 amends Normative Instruction 1,681/2016 relating to guidance on CbC reporting. According to NI 1,722/2017, transitional provisions apply if a legal entity
See MoreRussia submits draft law on automatic international exchange of tax information including documentation requirements
The Russian Government on 20 July 2017, submitted the draft bill (Bill No. 231414-7) on the automatic international exchange of tax information to the Russian State Duma. The draft bill proposes amendments to the Tax Code, which are necessary for
See MoreIndia introduces CbC reporting requirements
India has included a country-by-country (CbC) reporting requirement in section 286 of the Indian Income-tax Act, 1961, with effect from the financial year 2016-2017. The requirements are principally in line with BEPS Action 13. The first round of
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