Australia: New guidelines for Local and Master file for 2018

15 July, 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

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Peru: Tax administration issues resolution regarding master file and CbC reporting requirements

12 July, 2018

The tax administration (Superintendencia Nacional de Administración Tributaria, SUNAT) issued Resolution 163-2018/SUNAT (the Resolution) on 29 June 2018 which was published in the Official Gazette. The Resolution sets out the rules for preparing

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Hong Kong: Legislative council passes the transfer pricing legislation

08 July, 2018

On 4 July 2018, the Legislative Council adopted the new transfer pricing regime ((Amendment) (No. 6) Bill 2017 (the “BEPS Bill”)). During the legislative process, some changes were made to the initial bill. Remarkable changes are the possible

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Belgium: Notification for corporate tax compliance

24 June, 2018

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

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Latvia: Cabinet Ministers approves a draft bill on Master and Local file

24 May, 2018

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

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Kazakhstan: State Revenue Authority announces introduction of TP documentation

02 May, 2018

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

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India: The deadline for multinationals to submit a master file and CbC report is 31 March

15 March, 2018

The due date for multinationals in India to furnish a country-by-country (CbC) report and masterfile for the accounting year 2016-17 is 31 March 2018. The master file must be submitted on Form 3CEAA. Part A of the form is required for all

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India: CbC reporting changes made in Finance Bill 2018 as passed by the Lok Sabha

15 March, 2018

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

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Finland: Tax administration publishes new guidance on TP documentation

11 February, 2018

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

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Taiwan: MoF announces Safe harbor exemption

29 January, 2018

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

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Denmark introduces new deadline for transfer pricing documentation

25 January, 2018

On 7 December 2017 the Danish Parliament passed a new law (No. L 13) launching a deadline for preparing and submitting the transfer pricing documentation. The most important changes are: The new law requires to prepare the transfer pricing

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Kazakhstan: Tax Law Reforms for the year 2018

24 January, 2018

The Kazakh President, signed a series of laws on 25 December 2017 regarding taxes and other mandatory payments, introduction of tax code, law on amendments to other Acts etc. Most provisions of the new tax code and the tax amendments effects from 1

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Russia publishes final law on automatic exchange of tax information and documentation requirements

12 December, 2017

Recently, the Federal Law No. 340-FZ of 27 November 2017, amending the Tax Code in relation to the implementation of the international automatic exchange of financial accounting information and transfer pricing (TP) documentation of multinational

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Pakistan: FBR publishes rules for documentation and CbC reporting requirements

26 November, 2017

On 16 November 2017, the Federal Board of Revenue (FBR) in Pakistan has published SRO 1191(1)/2017, which includes chapter VIA to the Income Tax Rules of 2002. The new Chapter (VIA) identifies the reporting entities, clarifies the reporting

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Taiwan: MoF announces changes to the transfer pricing documentation rules

18 November, 2017

The Ministry of Finance (MoF) published the amendment of Transfer Pricing Audit Rules on 13th November 2017. The rules established three-tiered transfer pricing documentation in accordance with the OECD under the base erosion and profit shifting

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Hungary: New transfer pricing Decree on Transfer Pricing Documentation rules

14 November, 2017

On 18 October 2017, the Hungarian Ministry of National Economy (NGM) issued a decree on new Transfer Pricing Documentation rules. According to the provisions of the Decree, a group is required to prepare a master file and a local file from fiscal

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India: CBDT publishes rules for CbC reporting and Master File rule

03 November, 2017

On 1 November 2017, the Central Board of Direct Taxes (CBDT) has notified rules in respect of Country-by-Country reporting and furnishing of Master File. The significant features of the Country-By-Country Report and Master File rules are: The

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India: CBDT publishes the Final Rules for CbC reporting and the furnishing of the master file

01 November, 2017

On 31 October 2017, the Central Board of Direct Taxes (CBDT) published the Final Rules for country by country (CbC) reporting and the furnishing of the master file. The Final Rule contain a few administrative changes and clarifications. However, the

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