Panama introduces CbC registration process via AEOI portal

31 January, 2020

The FATCA & AEOI Portal of Panama's Directorate General of Revenue (DGI) is now accepting registration for Country-by-Country (CbC) report presentation and notification purposes, as well as for FATCA and CRS purposes. The CbC reporting

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Dominican Republic: DGII issues transfer pricing documentation thresholds for 2020

23 January, 2020

On January 15, 2020, Directorate General of Internal Revenue (DGII) published the Transfer pricing (TP) reporting threshold for 2020. The related party transaction threshold for transfer pricing reporting purposes in 2020 is DOP11,552,402. The

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Canada: Reminder for the CbC reporting form submission process

22 January, 2020

On 9 January 2020, Government announced that as from 1st June 2020, Canadian ultimate parent entities that are corporations must file the RC4649 electronically using EFILE or Web Access Code (WAC). It will be available through CRA-T2-certified

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India: CBDT issues notification to amend the rules for furnishing master file and CbCR

22 January, 2020

On 6 January 2020, India’s Central Board of Direct Taxes issued a notification amending the rules for maintenance and furnishing of information and document made by constituent entities of international groups. The amendments mainly clarifies the

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Colombia publishes a decree on tax return and TP documentation deadline

20 January, 2020

On 23 December 2019, Colombian tax authority (DIAN) has published Decree No. 2345 specifying the deadlines for filing and payment of the tax return (declaration) for 2020 and the deadline for transfer pricing (TP) documentation, including

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Austria: Government publishes Program for 2020-2024 regarding tax measures

15 January, 2020

The Government released its Program for 2020-2024 regarding several tax reform measures. Corporate tax The Program proposed to increase the threshold of corporate income tax from EUR 30,000 to EUR 100,000 and reduce the corporate income tax

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Sri Lanka: IRD declares CbC reporting and notification deadline

14 January, 2020

On 17 December 2019, the Inland Revenue department (IRD) of Sri Lanka has issued a notice on the filing of Country-by-Country (CbC) reports by MNE groups. According to Regulation 6 of the Extraordinary Gazette No. 2104/4 of 31

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South Korea: National Assembly enacts tax reform bill for 2019

13 January, 2020

On 31 December 2019, South Korea’s National Assembly has enacted tax reform bill for 2019 with a number of new measures added to the existing proposals including changes in transfer pricing measures. The new and amended tax measures are

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Hong Kong: IRD extends CbC reporting deadline for local filing

01 January, 2020

On 18 December 2019, Inland Revenue Department announced an extension to the due date for local filing of some country-by-country tax reports. The local filing requirement applies to a relevant accounting period beginning on or after 1 January

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Panama extends CbC reporting deadline and notification

31 December, 2019

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

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Qatar publishes new regulations to amend income tax law

28 December, 2019

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

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Germany: Federal Ministry of Finance publishes a draft law with significant changes to TP rules

25 December, 2019

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

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Argentina: AFIP declares further extensions to TP filing deadlines

21 December, 2019

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

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Saudi Arabia introduces E-Service for CbC reporting

16 December, 2019

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

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Serbia: Parliament amends the corporate income tax law including CbCR obligations

16 December, 2019

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

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Taiwan: MOF announces safe harbor rules for CbC report

15 December, 2019

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

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Bulgaria: Government publishes Law on Amendments to the Corporate Income Tax Act

12 December, 2019

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

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Bulgaria legislates amendments to the TP documentation threshold

09 December, 2019

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

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