Kazakhstan: State Revenue Authority announces introduction of TP documentation
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
See MoreZambia: Government publishes new transfer pricing regulations
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
See MoreIndonesia launches electronic system for CbC report submission
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
See MoreTaiwan: Government clarifies transfer pricing documentation thresholds
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
See MoreUS: IRS publishes a notice concerning CbC reporting requirements of certain U.S. MNE groups
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
See MoreIndia: President approves Finance Act 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
See MoreAustralia: Minimum interest rate for simplified transfer pricing record keeping for 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
See MoreIndia publishes clarification regarding requirement for furnishing CbC report
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
See MoreIndonesia: New guidance on CbC reporting
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
See MoreArgentina: CbC notification deadline extends for fiscal years ending
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
See MoreKorea: Increased noncompliance penalties on transfer pricing documentation requirement
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
See MorePoland extends the deadline for Transfer Pricing documentation
The Ministry of Finance (MoF) released the Regulation of the Minister of Finance of 14 March 2018 regarding the extension of the deadline for taxpayers to comply with certain transfer pricing documentation obligations on 15th March 2018 in the
See MoreSingapore: New transfer pricing rules
Singapore Inland Revenue Authority published transfer pricing documentation rules and transfer pricing guidelines in February 2018. The major expansions of the transfer pricing rules are as follows: The arm’s length principle is aligned with
See MoreRussia approves bilateral exchange agreements for CbC reports
The Government of the Russian Federation has published Decree No. 184 of 21 February 2018, which amends Decree No. 805 of 14 August 2014 on the conclusion of agreements for the exchange of information in tax matters. The changes include the
See MoreIndia: The deadline for multinationals to submit a master file and CbC report is 31 March
The due date for multinationals in India to furnish a country-by-country (CbC) report and masterfile for the accounting year 2016-17 is 31 March 2018. The master file must be submitted on Form 3CEAA. Part A of the form is required for all
See MoreIndia: CbC reporting changes made in Finance Bill 2018 as passed by the Lok Sabha
On 14 March 2018, the lower house of parliament (Lok Sabha) has approved the Finance Bill 2018 with modifications. One of the main changes includes by the bill is changes to the country-by-country (CbC) reporting and Master file requirements. The
See MoreHong Kong introduces CbC reporting portal
On 5 March 2018, Hong Kong government announced that it has launched its country-by-country reporting portal. Hong Kong Ultimate Parent Entities of Reportable Groups (HK UPEs) can now file CbC Returns for accounting periods beginning between 1
See MoreSingapore: Published Country-by-Country Reporting regulations
The Government of Singapore published Country-by-Country Reporting in the Singapore Government Gazette the “Income Tax Regulations 2018” on 5 February under the Income Tax Act (ITA). Country-by-Country reporting application and
See More