India: 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 MoreSingapore: IRA releases revised transfer pricing guidelines
On 23 February 2018, Inland Revenue Authority issued the fifth edition of its transfer pricing guidelines outlining the improvements to the arm’s length principle, adding new transfer pricing documentation requirements, and granting new powers of
See MorePoland: MoF issues guidance on preparation of transfer pricing documentation
Poland's Ministry of Finance (MoF) has published general interpretation no. DCT.8201.1.2018 regarding thresholds for the obligation to prepare transfer pricing documentation on 31st January 2018. According to general interpretation
See MorePakistan issues more draft amendments to CbC reporting requirements
On 9 February 2018, the Federal Board of Revenue (FBR) in Pakistan has published SRO no. 144(I)/2018, which provides more amendments to draft rules that establish transfer pricing documentation and country-by-country reporting rules for large
See MoreIndia: Budget 2018 proposes rules for implementation CbC reporting requirements
On 1 February 2018, the Finance Minister presented the Union Budget 2018. The budget includes proposals to clarify rules for implementation of the country-by-country (CbC) reporting requirements. Consequently, the due date for submits the CbC
See MoreFinland: Tax administration publishes new guidance on TP documentation
On 29 January 2018, the tax administration issued the new guidance No.A129/200/2017 on transfer pricing documentation, which replaces the previous guidance of 2007. The documentation requirement is divided into a master file and a local file. The
See MoreCosta Rica: Tax administration Gazettes CbC reporting resolution
On 2 February 2018, Costa Rica published the Resolution no.DGT-R-001-2018. Resolution No.DGT-R-001-2018 requires multinationals to submit a CbC report in accordance with the OECD's recommendations for the erosion and profit shifting base (BEPS)
See MorePakistan: FBR publishes amendments to CbC reporting requirements
On 31 January 2018, the Federal Board of Revenue (FBR) in Pakistan has published SRO no. 99(I)/2018, which provides amendments to draft rules that establish transfer pricing documentation and country-by-country (CbC) reporting requirements for large
See MorePeru: Tax authority issues ruling on deadline for submitting local file
On 18 January 2018, the Peruvian tax authorities (SUNAT) issued Ruling N° 014-2018/SUNAT requiring taxpayers to electronically submit the local file on an annual basis in June of the following year. The due date for the submission of the first
See MoreTaiwan: MoF announces Safe harbor exemption
Taiwan's Ministry of Finance (MoF) announced a “safe harbor” exemption with respect to Master file and country-by-country (CbC) reporting On 11th December 2017. Transfer pricing guidance issued in November 2017 (and known in English as
See MoreIndonesia: CbC Reporting implementing regulations
The Director General of Taxation (the DGT) of Indonesia issued DGT Regulation 29/PJ/2017 (PER-29) concerning implementing regulations on Country-by-Country (CbC) Reporting requirements, effective as of 29 December 2017. PER-29 provides some clarity
See MoreNigeria: Government signs CbCR Regulations 2018 to follow-up MCAA
The Federal Government has signed the Income Tax Regulations or Country-by-Country Reports (CbCR), 2018. The Regulations are part of the implementation plans under Action 13 of OECD’s Base Erosion and Profit Shifting (BEPS) project. This is also
See MoreDenmark 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.
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