Panama extends CbC reporting deadline and notification
On 27 December 2019, Directorate General of Revenue of Panama has issued Resolution No. 201-9116 and 201-9117, with effect from the date of publication. Resolution No. 201-9116 extends the filing of Country by Country (CbC) reporting until 31
See MoreQatar publishes new regulations to amend income tax law
On 11 December 2019, Qatar published Executive regulations 39/2019 in the Official Gazette, introduced new Income Tax Law No. 24 of 2018. The new regulations are generally effective from 12 December 2019. Key features of the new regulations
See MoreGermany: Federal Ministry of Finance publishes a draft law with significant changes to TP rules
On 10 December 2019, Germany published a draft law implementing EU anti-tax avoidance directive. The Draft Law includes significant changes to the German transfer pricing rules. The following proposed changes have been taken place under the
See MoreArgentina: AFIP declares further extensions to TP filing deadlines
On 16 December 2019, the Tax Authority (AFIP) announced further extensions to timeline to transfer pricing (TP) filing returns for the financial years ending on December 31, 2018. Previously, under General Resolution 4538/2019 of 30 July 2019
See MoreSaudi Arabia introduces E-Service for CbC reporting
Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia have introduced E-Service for country-by-country (CbC) reporting. As per the transfer pricing Bylaws, Saudi Arabian taxpayers that are members of an MNE Group with consolidated
See MoreSerbia: Parliament amends the corporate income tax law including CbCR obligations
On 6 December 2019, the Serbian Parliament passed the legislation that amends the corporate income tax law including requirements for country-by-country (CbC) reporting of controlled transactions within a corporate group. The Law is published in
See MoreTaiwan: MOF announces safe harbor rules for CbC report
On 10 December 2019, the Ministry of Finance (MOF) issued tax ruling no. 10804651540 providing exemption from CbC reporting for Taiwan entities under a MNE Group headquartered outside Taiwan. The safe harbor exemption guidance was issued in late
See MoreBulgaria: Government publishes Law on Amendments to the Corporate Income Tax Act
On 6 December 2019, Law on Amendments to the Corporate Income Tax Act was published in the Official Gazette and it was adopted by the National Assembly on 21st November 2019. Similar amendments in Controlled Foreign Company (CFC) and transfer
See MoreBulgaria legislates amendments to the TP documentation threshold
On 6 December 2019, the Bulgarian Government published the amendments to the Act on Tax and Social Security Procedures in the Official Gazette. According to the amendments, the obligation to prepare such documents from 1 January 2020 will not apply
See MoreDenmark publishes the Bill no. L 48 on international taxation
On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. The bill updated the existing PE (permanent establishment) rules, CFC rules and strengthen the Transfer pricing (TP) rules. PE rules: The
See MoreBulgaria approves changes to the TP documentation threshold
On 21 November 2019, the Bulgarian parliament approved amendments to the thresholds for mandatory preparation of a local transfer pricing file. According to the amendments, the obligation to prepare such documents from 1 January 2020 will not
See MoreUS: IRS issues a notice requesting comments on CbC form
On 6 November 2019, the US Internal Revenue Service (IRS) published a notice requesting comments concerning IRS Form 8975 regarding CbC report. The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent
See MoreCyprus amends the company law introducing administrative penalties
On November 1, 2019, the Registrar of Companies published a notice regarding the implementation of Law 149 (1) / 2018 (the Act). The law amends company law and company law regulations with the introduction of administrative penalties on certain
See MoreSouth Africa: SARS publishes list of jurisdiction with effective CbC report exchange agreements
The South African Revenue Service (SARS) published a latest list of jurisdictions. These listed jurisdictions have CbC report exchange agreements with South Africa from 18 October 2019. The list is intended to assist members of the MNE groups
See MoreAustralia extends TP document submission deadline
Significant global entities (SGEs) that have a CbC reporting obligation in Australia for the year ended 31 December 2018 required that their local file (LF), master file (MF), and CbC report are due to be lodged by 31 December
See MoreCosta Rica publishes a resolution outlining guideline on transfer pricing documentation
On 13 November 2019, the Costa Rican tax authority released a Resolution No.DGT-R-49-2019 providing new guidelines on transfer pricing documentation including master file and local file. The new resolution repeal the resolution DGT-R-16-2017
See MoreSerbia: Parliament adopts draft bill to implement CbC reporting obligations
On 18 October 2019, the Serbian parliament accepted for consideration a bill to implement country-by-country (CbC) reporting obligations for multinational entities (MNEs). Under this ultimate parent entities of an MNE group resident in Serbia are
See MoreBulgaria submits proposal to amends the TP documentation threshold
On 12 November 2019, some of policy makers submitted to Parliament a proposal to amend the rules on thresholds for the Transfer Pricing (TP) documentation rules. It is proposed that the obligation to prepare such documents will not apply to persons
See More