Malaysia: 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
See MoreItaly: Italian Revenue Agency taking implementing procedures for Country-by-Country Reporting (CbCR)
New law has been introduced by the Italian Revenue Agency for the execution of CbCR concerning the medium of presentation of the reports in Italy which is in the same radar with the OECD recommendations and the EU Directions. It is mainly implied on
See MoreFinland: Government proposes to align CbC reporting with EU Directive
On 19 December 2017, Bill No. 191/2017 was submitted to the parliament as a proposal to amend section 14 d of the Act on Taxation Procedure which is in line with Council Directive (EU) 2016/881 of 25 May 2016 amending Directive 2011/16/EU. The
See MoreItaly: Tax authority extends the due date for filing the CbC report
On December 11, the tax authority issued a Measure n. 288555 extending the due date for filing the CbC report for fiscal year 2016 from 31 December 2017 to 9 February 2018 within 60 days following the measure’s publication
See MoreCyprus: Government extends the deadline for submitting CbC reports for fiscal years 2016 and 2017
On 11 December 2017, the Cyprus Tax Department issued two notices with extensions of the deadline for submission of CbC reports for the fiscal years 2016 and 2017. The deadline for submission of country by country reports for fiscal year 2016 is the
See MoreArgentina: Comprehensive tax reform enacts
The Law No. 27430 or comprehensive tax reform was published on December 29, 2017 in the Official Gazette and it generally applies from January 1, 2018. This comprehensive tax reform bill has sent to Congress on December 14, 2017. The Ministry of the
See MoreRomania: National tax administration publishes electronic forms of the CbC report
On 11 December 2017, the Romanian National Tax Administration Agency published on its website the electronic forms of the CbC report and the CbC report notification templates to be used for submission by the Romanian taxpayer forms R404 and R405,
See MoreSouth Africa: SARS extends deadline for filing of Country-by-Country reports
On 8 December 2017, the South African Revenue Service (SARS) announced that it extended the Country-by-Country report, master file and local file reporting deadline to 28 February 2018 for taxpayers with an existing reporting obligation in December
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