South 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 MoreDominican Republic: Executive Branch submits 2020 draft budget bill to the National Congress
On 1st October 2019, the Executive Branch sent 2020 draft budget bill to the National Congress the 2020 draft budget bill for its knowledge, discussion and approval. The bill proposes measures to extend the rules on interest deduction and
See MoreSlovak Republic: Implementing mandatory disclosure rules
On 14 October 2019, the Government of Slovak Republic published in the Collection of Laws the final legislation that transposes the Directive on Administrative Cooperation in Taxation (DAC6) commencing Mandatory Disclosure Rules (MDR). On
See MorePeru: SUNAT publishes resolution on submission of CbC reports
On 29 September 2019, the Peruvian Tax Administration (SUNAT) has published Resolution No. 188-2019/SUNAT in the Official Gazette, through which the comprehensive system for the reception and automatic exchange of information (IR AEOI system) was
See MoreArgentina: AFIP announces draft transfer pricing guidance for public comments
On 2 October 2019, tax authority of Argentina (AFIP) announced a public consultation and posted on the AFIP website a draft resolution concerning transfer pricing compliance procedures. It would replace the existing transfer pricing rules in
See MoreNigeria: FIRS introduces e-filing for submitting TP returns
On 27 September 2019, Federal Inland Revenue Service (FIRS) described the way of how to submit transfer pricing (TP) returns through the electronic platform, when it is active. Now, the FIRS is get ready to automate the process of filing TP
See MoreGreece: AADE publishes Circular 1341 / 09-09-2019 on CbC notification process
On 17 September 2019, the Greek Public Revenue Authority (AADE) released a Circular 1341 / 09-09-2019 containing amendments to Decision POL. 1184 of 22 November 2017 regarding the submission process of CbC notifications. Under this new Circular,
See MorePortugal publishes changes to various Tax Codes
On 18 September 2019, the Portuguese Government officially published the Law no.119/2019. The new law has changed the following provisions: Corporate income tax: The procedure whereby non-resident companies may waive all or part of the
See MoreDenmark: Draft bill on international taxation submits for public comments
On 12 September 2019, the Ministry of Taxes published a major bill on international taxation. The bill will be subjected to a public hearing and subsequently presented to the Danish Parliament. Interested parties can submit their comments by 10
See MoreSaudi Arabia: GAZT requests for TP documentation
Recently, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia have requested the taxpayers to submit specific transfer pricing (TP) documentation (master file and local file) in relation to the fiscal year ending 31 December
See MoreRomania introduces mandatory online submission for CbC Reporting
On 19 August 2019, Romania has published Order No. 2.273, amending the rules on submission of Country-by-Country (CbC) reports and notifications, effective from 26 August 2019. Now both CbC reports and notifications must be submitted through
See MoreHong Kong: IRD updates penalty provisions for international tax
On 4 September 2019, the Hong Kong Inland Revenue Department updated its web page on penalty policies related to international tax matters, including fines and criminal penalties, for noncompliance with international tax obligations. The
See MoreItaly updates CbC reporting requirements
On 8 August 2019, Italy has published the Ministerial Decree in the Official Gazette amending the Ministerial Decree of 23 February 2017 regarding Country-by-Country reporting (CbCR). The Decree amends Article no. 7 on the use of CbC
See MoreBulgaria publishes new mandatory TP documentation requirements
On 13 August 2019, amendments to the Tax and Social Security Procedure Code (TSSPC) were published in the State Gazette. The law introduced the mandatory new transfer pricing (TP) documentation requirements in Bulgaria. Documentation
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