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 MorePeru: SUNAT extends deadline for submission of CbC report to March 2019
On 11 November 2018, Peruvian tax authorities (SUNAT) published Ruling No. 264-2018 SUNAT which extended the due date for submitting CbC report from November 2018 to March 2019 for fiscal year 2017. The extension applies to Peruvian taxpayers who
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 MorePoland: Parliament passes tax reform bill for 2019 including MDR
On 26 October 2018, the upper house of the Polish Parliament (the Senate) adopted the draft bill introducing far-reaching changes to the Polish tax law, including European Union (EU) Mandatory Disclosure Rules (MDR). The main difference of the
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 MoreArgentina: AFIP publishes information regarding CbC reporting
On October 24, 2018, the tax authority (AFIP) published information regarding Country-by-Country (CbC) reporting in their website. Two information regimes are implemented in order to combat tax evasion and avoidance and the transfer of benefits to
See MoreOECD: Tax Talk discusses progress on key tax issues
An OECD Tax Talk on 16 October 2018 discussed the latest developments on tax issues. Tax Challenges of Digitalisation In March 2018 the Task Force on the Digital Economy (TFDE) sent an interim report to the G20 on the tax challenges of
See MorePakistan: SECP publishes requirements for companies to maintain record of all related party transactions
On 2 October 2018, the Securities and Exchange Commission of Pakistan (SECP) has issued SRO 1194(I)/2018 to introduce Companies (Related Party Transactions and Maintenance of Related Records) Regulations, 2018. These Regulations are applicable on
See MoreNigeria: FIRS issues public notice regarding deadline set for TP documentation
The Federal Inland Revenue Service (FIRS) has previously released the Income Tax (Transfer Pricing) Regulations, 2018, which replaced the Income Tax (Transfer Pricing) Regulations, 2012. The 2018 TP Regulations, which introduced supplementary
See MoreThailand: National Legislative Assembly publishes revised draft transfer pricing act
On 27 September 2018, National Legislative Assembly released the revisions to the draft Transfer Pricing Act (the draft TP Act). The revenue threshold for subject to transfer pricing documentation is THB200 million (US$6 million) per year
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 MoreQatar: MoF implements new CbC requirements through Decision No. 21 of 2018
The Ministry of Finance published a Decision No. 21 of 2018 on September 9, 2018 in the Official Gazette. This Decision implements new Country-by-Country (CbC) reporting requirement. It is effective from September 10, 2018. A CbC report contains
See MoreNigeria: FIRS publishes a public notice regarding CbC Regulations
The Federal Inland Revenue Service (FIRS) issued a public notice on September 17, 2018. This notice provides alert that income tax country-by-country (CbC) reporting regulations S.I. no. 6, 2018 entered into force with effective from January 1, 2018
See MoreSingapore: IRAS publishes e-tax guide on country-by-country reporting
On 7 August 2018, the Inland Revenue Authority of Singapore (IRAS) published the third edition of its e-Tax Guide concerning country-by-country reporting. The purpose of the guide is to provide information to the taxpayers regarding the obligation
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 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 MoreFrance: Tax authority publishes transfer pricing guidelines related to BEPS compliance
On 18 July 2018, the French tax authorities published instructions regarding Master / Local file in the context of transfer pricing documentation. As per the guidelines, the new documentation requirements apply for fiscal years beginning on or
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