Lithuania gazettes new Transfer Pricing rules for 2019
On 31 December 2018, the Lithuanian Official Gazette published an order for the transfer pricing (TP) rules. The new requirements generally reflect measures implementing recommendations under the OECD’s base erosion and profit shifting (BEPS)
See MoreSaudi Arabia: General Authority of Zakat and Tax (GAZT) publishes draft transfer pricing law
On 10 December 2018, General Authority of Zakat and Tax (GAZT) released draft transfer pricing regulations (TPBy-laws) for public consultation. The regulations broadly follow international standards, including the arm’s-length principle and
See MoreBelgium extends transfer pricing documentation deadline
On 7 December 2018, the Federal Service for Finance of Belgium extended the deadline for submitting master file (275MF) and local file (275LF) from 31 December 2018 to 28 February
See MoreAustralia: 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 MoreBulgaria: 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 MoreLatvia: Parliament adopts regulation with new requirements for transfer pricing documentation
On 25 October 2018 the Parliament approved amendments to the law ‘On taxes and duties’ which introduce in Latvia the OECD format of the transfer pricing documentation. The law was published on 14 November 2018 as the official Gazette no
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 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 MorePoland releases draft law amending transfer pricing rules
On 16th July 2018, Poland has released a bill to amend the country's transfer pricing rules in line with the results of the BEPS project and the OECD transfer pricing guidelines 2017 in order to improve the taxation of large multinational companies.
See MoreAustralia: New guidelines for Local and Master file for 2018
The Australian Taxation Office (ATO) has published Local file instructions 2018 and Local file/master file 2018 to provide guidance for taxpayers to comply. The local file must be electronically lodged in the approved form (an XML file generated
See MoreBelgium: Notification for corporate tax compliance
As the first half of 2018 almost ends, it is time to look forward to the coming second installment of prepayments. Income tax returns The income tax authorities confirmed the deadline of the filing of corporate income tax returns with a financial
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 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 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 MoreFinland: Tax administration publishes new guidance on TP documentation
On 29 January 2018, the tax administration issued the new guidance No.A129/200/2017 on transfer pricing documentation, which replaces the previous guidance of 2007. The documentation requirement is divided into a master file and a local file. The
See MorePeru: Tax authority issues ruling on deadline for submitting local file
On 18 January 2018, the Peruvian tax authorities (SUNAT) issued Ruling N° 014-2018/SUNAT requiring taxpayers to electronically submit the local file on an annual basis in June of the following year. The due date for the submission of the first
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