Finland: 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.
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
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