Bulgaria: MoF proposes new mandatory documentation rule for transfer pricing
On 5 November 2018, the Ministry of Finance (MoF) published a draft consultation, proposing new mandatory documents for transfer pricing documentation, and a penalty for failure to comply with up to 1% of the value of undocumented transactions. The
See MoreZambia: Finance Minister presents National Budget 2019
On 28 September 2018, Zambia’s Minister of Finance, Hon. Margaret Mwanakatwe presented the 2019 National Budget to Parliament. The time period for making transfer pricing assessment may be raised for a period exceeding 6 years but not exceeding 10
See MoreBelgium: Ministry of Finance publishes decree on transfer pricing documentation penalties
On 2 August 2018, the Belgian Ministry of Finance published the Royal Decree of 29 June 2018 on administrative penalties for transfer pricing documentation. Taxpayers who do not meet the reporting and registration requirements for transfer pricing
See MoreNigeria: FIRS publishes Income Tax (CbC Reporting) regulations
The Federal Inland Revenue Service (FIRS) has released the Income Tax (Country-by-Country Reporting (CbCR)) Regulations on June 19, 2018. It was published in an official gazette on January 8, 2018. This CbCR Regulations give guidelines to
See MoreLatvia: Cabinet Ministers approves a draft bill on Master and Local file
Recently, the Latvia Cabinet of Ministers has approved a draft law for the introduction of Master and Local file requirements in line with BEPS Action 13. Under the law, taxpayers resident in Latvia are required to submit Master file within 12
See MoreSouth Africa: SARS issues notice on penalties for non-compliance of CbC report
On 11 May 2018, the South African Revenue Service (SARS) released a notice concerning penalties which provides taxpayer fails to submit returns (CbC report, Master File, Local file) by the deadline will be subject to a fixed penalty up to ZAR 16,000
See MoreZambia: Government publishes new transfer pricing regulations
Zambia published the income tax (transfer pricing) (Amendment) regulations under Statutory Instrument No. 24 of 2018 in the official gazette on 6th April 2018. The 2018 regulations conduct transfer pricing transactions between related entities as
See MoreArgentina: CbC notification deadline extends for fiscal years ending
A Resolution entitled “General Resolution 4218 of 23 March 2018” was published in the Official Gazette. This gives an extension of the established term for the Country-by-Country (CbC) information system and also the due date to submit the
See MoreKorea: Increased noncompliance penalties on transfer pricing documentation requirement
Korea has increased noncompliance penalties on transfer pricing documentation requirement. Taxpayers who fail to file a Combined Report of International Transactions (CRIT) or file false information are subject to penalties of KRW10 million
See MoreSingapore: New transfer pricing rules
Singapore Inland Revenue Authority published transfer pricing documentation rules and transfer pricing guidelines in February 2018. The major expansions of the transfer pricing rules are as follows: The arm’s length principle is aligned with
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 MoreSingapore: IRA releases revised transfer pricing guidelines
On 23 February 2018, Inland Revenue Authority issued the fifth edition of its transfer pricing guidelines outlining the improvements to the arm’s length principle, adding new transfer pricing documentation requirements, and granting new powers of
See MoreKorea Rep OF: Legislation of Tax Reform Bill 2018
On 19 December 2017, Korea passed the 2018 Tax Reform Act (the 2018 tax reform) after it was passed by the Korean National Assembly on 5 December 2017. The tax reform 2018 contains provisions in line with the BEPS Action 2 and Action 4 of the OECD.
See MoreArgentina: Government reforms transfer pricing rules via Decree 1112/2017
The government has issued a Decree No.1112/2017 on December 29, 2017, for enacting and making effective of comprehensive tax reform. It also contains the new rules for transfer pricing. According to the new Law, transactions with parties in low-tax
See MoreArgentina: Comprehensive tax reform enacts
The Law No. 27430 or comprehensive tax reform was published on December 29, 2017 in the Official Gazette and it generally applies from January 1, 2018. This comprehensive tax reform bill has sent to Congress on December 14, 2017. The Ministry of the
See MoreGreece: Revenue Authority publishes guide on submission of CbC reports
The Public Revenue Authority (AADE) published a guide to frequently asked questions (FAQs) on December 15, 2017 for describing clarifications on the country-by-country (CbC) reporting. This guide explains the step by step process and obligatory
See MoreCosta Rica: Tax administration publishes draft resolution on CbC reporting
On 26 October 2017, Costa Rica’s tax administration released a draft version of a resolution that would require multinational enterprises (MNEs) to file a country-by-country (CbC) report. According to draft resolution, all Costa Rican tax resident
See MoreSingapore: Income Tax (Amendment) Bill 2017 approved
The Income Tax (Amendment) Bill 2017 was approved by the Singaporean lawmakers on 2 October 2017.The amendments to the Income Tax Act comprise of tax changes announced in the 2017 Budget. According to the approved Bill existing corporate income tax
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