Denmark introduces new deadline for transfer pricing documentation
On 7 December 2017 the Danish Parliament passed a new law (No. L 13) launching a deadline for preparing and submitting the transfer pricing documentation. The most important changes are: The new law requires to prepare the transfer pricing
See MoreFrance: Change in Transfer Pricing Documentation Requirements
French Parliament updated their transfer pricing documentation rules. Under the Finance Act for 2018, which was approved by the Parliament on 21 December 2017, French companies must submit the transfer pricing documentation for financial years
See MoreKorea Rep OF: Legislation of Tax Reform Bill 2018
On 19 December 2017, Korea passed the 2018 Tax Reform Act (the 2018 tax reform) after it was passed by the Korean National Assembly on 5 December 2017. The tax reform 2018 contains provisions in line with the BEPS Action 2 and Action 4 of the OECD.
See MoreKazakhstan: Tax Law Reforms for the year 2018
The Kazakh President, signed a series of laws on 25 December 2017 regarding taxes and other mandatory payments, introduction of tax code, law on amendments to other Acts etc. Most provisions of the new tax code and the tax amendments effects from 1
See MoreCroatia: Closing date of CbC report submission extends for first year
A notice regarding the submission of Country-by-Country (CbC) reports has been announced on 16 January 2017 by the Tax Administration. The authority announced that CbC reports submission deadline for the 2016 reporting fiscal year was extended to
See MoreUS: IRS updates information concerning country-by-country (CbC) reporting
On 18 January 2018, the IRS issued a release announcing updates and information regarding country-by-country (CbC) reporting requirements in the United States. Under the update list, IRS publishes new content on Country-by-Country (CbC) reporting
See MoreSweden publishes CbC reporting threshold rules
The Swedish Tax Agency published a guidance on companies' country-by-country reporting (CbC) obligations with respect to short and extended tax years, and company divestments and restructurings on 15 January 2018. The guidance provides following
See MoreMalaysia: IRBM updates the rules for CbC reporting
The Inland Revenue Board (IRB) has recently published an amendment to the country-by-country (CbC) rules. Among the changes, the amended CbC rules include revised measures regarding entities having cross-border transactions with other constituent
See MoreThailand: Cabinet approves draft Transfer Pricing Act
On 3 January 2018, the Thai Cabinet approved the draft transfer pricing act following a public hearing held in July 2017 on the first draft Act that was approved in principle in May 2015. Subject to a legislative procedure and announcement, the
See MoreColombia issues regulations on CbC reporting notification requirement
The tax authority of Colombia (DIAN) published Decree 2120 of 15 December 2017 concerning the obligation for taxpayers to inform the tax authorities whether they are required to file the Country-by-Country (CbC) report. The CbC report filing
See MorePortugal: Requirements for the preparation and exchange of Country-by-Country Reports published
On 21 December 2017, Portuguese Orders number 383-A/ 2017 and 383-B/2017 were published in the Official Gazette. Order number 383-A/2017 approved form 55 containing the CbC report. Form 55 must be submitted electronically on an annual basis and
See MoreSpain amends the CbC reporting rules to align with EU Directive
On 30 December 2017, Royal Decree 1074/2017 amending the corporate tax rules and other provisions was published in the Official Journal. Royal Decree 1074/2017 amends, among other things, the Spanish CbCR rules in order to better align them with EU
See MoreHong Kong publishes a bill to implement transfer pricing documentation
On 29 December 2017, Inland Revenue (Amendment) (No. 6) Bill 2017 published in order to sets out rules on transfer pricing documentation including country-by-country reporting, and contains other measures to implement the minimum standards under
See MoreSpain: Council of Ministers approves the amendment of several tax regulations
On 29 December 2019, the Council of Ministers approved a Royal Decree-Law to extend and approve various tax measures and other urgent measures on social issues, which provides for the coefficients to update cadastral values for 2018. The Decree
See MoreArgentina: Government reforms transfer pricing rules via Decree 1112/2017
The government has issued a Decree No.1112/2017 on December 29, 2017, for enacting and making effective of comprehensive tax reform. It also contains the new rules for transfer pricing. According to the new Law, transactions with parties in low-tax
See MoreItaly: Approval of 2018 Budget Bill including new tax on digital services
The main agenda of this Bill being approved by the Italian Senate was to offset differences on tax on digital services so that it can target large multinational companies like Facebook, Apple and Google providing digital services in Italy. Italy has
See MoreHungary: Deadlines of Country-by-Country reporting and notification requirements
Issues have been generating recently on filling Hungary’s CbC reporting notification on the 17T201T form. A Hungarian resident entity is not required to file the CbC notification requirement until or unless the multi-national group has a
See MoreFrance: US Multinational Groups and the French Country-by-Country reports
The United States hasn’t been yet included in the French Ministerial Order consisting of the list of states for CbCR purposes. Discussions on the authority agreement between France and USA are still going on, which has a bit of suspense running
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