US: IRS updates instructions for Country by Country reporting form
On 10 July 2019, IRS published the updated instructions for filing Form 8975 (Country-by-Country Report). Key changes are highlighted below; IRS Updates Mailstop for U.S. MNEs Filing Form 8975 on Paper: If a U.S. multinational enterprise
See MoreQatar: GTA issues additional CbC reporting obligations
On 16 June 2019, Qatar's General Tax Authority (GTA) has issued a notice prescribing further updates and clarifications for the Country-by-Country (CbC) reporting obligations in Qatar. Key points of CbC reporting obligations are as follows:
See MoreRussia: Parliament approves law on submission of CbC reports
On 7 June 2019, the Russian parliament passed Law No. 125-FZ in the Official Gazette. The Act amends Article 105.16.3 of the Tax Code on the submission of country-by-country (CbC) reports by multinationals (MNE). The amendments extend the list
See MoreAustralia provides additional 15 days for CbC statement lodgment
The Australian Taxation Office (ATO) has provided additional 15 days for the lodgment of CbC statements (Local File, Master File, CbC report) with 30 June 2019 due date because of technical issues. This additional time will apply automatically
See MoreSaudi Arabia: GAZT holds seminar to simplify the transfer pricing regulations
On 17 June 2019, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia has organized a transfer pricing seminar in Riyadh to simplify the key areas of the transfer pricing (TP) regulations published on 15 February 2019 and to address
See MoreColombia: DIAN publishes procedures to submit the TP return, Master file, Local file and CbC report
On 22 May 2019, the Colombian tax authority (DIAN) published regulations for the submission of the Local file and Master file, the Transfer pricing (TP) return, and the Country-by-Country (CbC) report notification corresponding to the 2018 tax year
See MoreNigeria: TP returns due on 30 June
It’s a reminder for the companies with a 31 December year-end required to file a transfer pricing (TP) return by 30 June 2019. Pursuant to the Transfer Pricing Regulations of 2018, existing companies with financial year-end of 31 December 2018
See MorePanama implements CbC reporting requirements
On 27 May 2019, the Ministry of Economy and Finance of Panama published Executive Decree No. 46 in the official gazette. The decree was issued regarding implementation of country-by-country (CbC) reporting with following
See MoreArgentina modifies TP documentation requirements
On 27 May 2019, the Federal Administration of Public Revenue (AFIP) has published General Resolution 4496 (GR 4496) in the official gazette amending General Resolution 1122 (GR 1122). The resolution explains requirements, deadline, thresholds for
See MoreBulgaria: Parliament adopts amendments to TP documentation bill at first-reading
On 5 June 2019, the Bulgarian Parliament adopted at first reading amendments to the Tax and Insurance Procedure Code, which introduced the new transfer pricing (TP) documentation requirements. One of the most important changes is in relation to
See MoreNew Zealand: Inland Revenue publishes revised transfer pricing regime
On 29 April 2019, Inland Revenue published the final versions of the special reports on the new rules for base erosion and profit shifting (BEPS). The rules were enacted in the Taxation (Neutralising Base Erosion and Profit Shifting) Act 2018 on 27
See MorePoland publishes law amending CbC reporting rules
On 15 April 2019, Poland published the Act of 4 April 2019 amending the Act on the exchange of tax information with other countries and certain other acts including Country-by-Country (CbC) reporting rules. Under this, if a group prepares its
See MoreBelgium Updates XML Tool and the XSD schema for Local File
The Belgian Federal Public Service (SPF) Finance has published an update version 2.1 of the XML tool and the XSD schema for the Transfer Pricing (TP) Local file (Form 275 LF), which must be used for Local files submitted via the MyMinfin platform
See MoreHungary: NTC publishes a notice to remind taxpayers for deadline of TPD
On 8 May 2019, the Hungarian National Tax and Customs Administration issued a notice to remind taxpayers that they must prepare their transfer pricing documentation by 31 May 2019 if they are required to keep transfer pricing records and closed
See MoreGermany updates Guidance on CbC reporting requirements
The German Ministry of Finance issued an updated version of the Application Decree on the General Tax Code on 5 April 2019. The updated version provides for guidance on the application of section 138a of the General Tax Code (GTC) by the tax
See MoreIndia: CBDT publishes new deadline for CbC Report Local Filing for U.S. MNEs
On 8 April 2019, the Central Board of Direct Taxes(CBDT) has issued Circular 7/2019 regarding the constituent entities of U.S. MNEs are required to submit Country-by-Country (CbC) reports in India by 30 April 2019. The circular notes that
See MoreDenmark approves deadlines for preparing, submitting transfer pricing documentation
Recently, the Danish parliament adopted an important amendment of the Tax Control Act (L 13 Forslag til Skattekontrollov of October 4, 2017) that is in force from January 1, 2019 with regard to transfer pricing documentation. The purpose of the
See MoreUruguay extends CbC Reporting deadline to 30 April 2019
According to Resolution No. 860/2019 of 27 March 2019, Uruguay's Directorate General of Taxation has extended the deadline for the submission of Country-by-Country Report (CbCR) to 30 April 2019 in respect of the reporting fiscal year ending 31
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