Kenya publishes draft income tax bill for 2018

27 May, 2018

National Treasury of Kenya has published the Draft Income Tax Bill 2018 for public comment. The draft Bill is intended to replace the current Income Tax Act with some certain provisions. Some of the main points are condensed as follows: Corporate

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Latvia: Cabinet Ministers approves a draft bill on Master and Local file

24 May, 2018

Recently, the Latvia Cabinet of Ministers has approved a draft law for the introduction of Master and Local file requirements in line with BEPS Action 13. Under the law, taxpayers resident in Latvia are required to submit Master file within 12

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Cayman Islands: DITC released official guidance on the CbC reporting requirements

22 May, 2018

The Cayman Islands’ Department for International Tax Cooperation (“DITC”) released their official guidance on March 29, 2018 regarding the Country-by-Country (“CbC”) reporting requirements of entities that are resident in the Cayman

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Russia approves format for CbC Reports and Notification for multinational groups

21 May, 2018

On 6 May 2018, Russia’s Federal Tax Services (FTS) issued Order No. MMV-7-17/123 and Order No. MMV-7-17/124 issued on 26 April 2018 in the Official Gazette. The orders approves the format and method of submission for Country-by-Country (CbC)

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South Africa: SARS issues notice on penalties for non-compliance of CbC report

20 May, 2018

On 11 May 2018, the South African Revenue Service (SARS) released a notice concerning penalties which provides taxpayer fails to submit returns (CbC report, Master File, Local file) by the deadline will be subject to a fixed penalty up to ZAR 16,000

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US and Indonesia sign MOU on the exchange of CbC reports

16 May, 2018

On April 26, 2018, the Internal Revenue Service issued a Memorandum of Understanding (MOU) between the Competent Authorities of the United States (US) and Indonesia, which includes an announcement of the temporary suspension of Indonesia's secondary

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Australia: ATO announces CbC reporting deadline for local file

10 May, 2018

The Australian Taxation Office (ATO) has released its final draft of the 2018 Message Structure Table (MST) and XML Schema for the Australian Local File (ALF) for tax year 2018. This will represent the second ALF that most taxpayers will be required

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Kazakhstan: State Revenue Authority announces introduction of TP documentation

02 May, 2018

The State Revenue Authority declared on April 25, 2018, about the introduction of a three-level method to transfer pricing documentation. The Kazakh President, signed a series of laws, including Law 122-VI on 25 December 2017 regarding transfer

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Zambia: Government publishes new transfer pricing regulations

25 April, 2018

Zambia published the income tax (transfer pricing) (Amendment) regulations under Statutory Instrument No. 24 of 2018 in the official gazette on 6th April 2018. The 2018 regulations conduct transfer pricing transactions between related entities as

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Indonesia launches electronic system for CbC report submission

17 April, 2018

On 13 April 2018, Directorate General of Taxation of Indonesia has declared the launch of the electronic submission system for Country-by-Country (CbC) reports via the DJP Online Portal. The system provides a step-by-step guideline for the

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Taiwan: Government clarifies transfer pricing documentation thresholds

15 April, 2018

On 1st April 2018, the Taiwanese government defined how companies should calculate transfer pricing disclosure and documentation thresholds when they operate less than a full year due to fiscal year change, merger, or acquisition. According to the

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US: IRS publishes a notice concerning CbC reporting requirements of certain U.S. MNE groups

11 April, 2018

On 30 March 2018, IRS released an advance copy of Notice 2018-31 concerning national security considerations with respect to country-by-country (CbC) reporting. In consideration of the national security interests of the United States, the notice

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India: President approves Finance Act 2018

10 April, 2018

On 29 March 2018, the Finance Bill 2018 received the approval of the president and now is enacted law, following some changes made by the lower house of parliament on 15 March 2018. This law would apply with effect from 1 April 2018. The main tax

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Australia: Minimum interest rate for simplified transfer pricing record keeping for 2018

08 April, 2018

The Australian Taxation Office (ATO) has updated its guidance on simplified transfer pricing record keeping options to include the minimum interest rate for the simplified option for low-level outbound loans for the 2018 income year, which is set at

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India publishes clarification regarding requirement for furnishing CbC report

28 March, 2018

On 23 March 2018, the Government of India published clarification regarding requirement for furnishing of Country-by Country Report under Section 286(4) of Income Tax Act, 1961. The government also confirmed that where a non-parent constituent

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Indonesia: New guidance on CbC reporting

28 March, 2018

On 26 March 2018, the tax authority of Indonesia published an updated guidance on Country-by-Country (CbC) reporting. The guidance includes: The general CbC reporting requirements applicable for MNE groups with consolidated gross revenue

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Argentina: CbC notification deadline extends for fiscal years ending

28 March, 2018

A Resolution entitled “General Resolution 4218 of 23 March 2018” was published in the Official Gazette. This gives an extension of the established term for the Country-by-Country (CbC) information system and also the due date to submit the 

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Korea: Increased noncompliance penalties on transfer pricing documentation requirement

27 March, 2018

Korea has increased noncompliance penalties on transfer pricing documentation requirement. Taxpayers who fail to file a Combined Report of International Transactions (CRIT) or file false information are subject to penalties of KRW10 million

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