Germany releases guidance on CbC reporting requirements

19 July, 2017

The Germany Federal Ministry of Finance on 11 July 2017 issued guidance on the Country-by-Country (CbC) reporting requirements in line with BEPS Action 13 and the EU Administrative Assistance Directive as amended. The guidance clarifies the

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US: IRS releases final versions of CbC form and instructions

17 July, 2017

The Internal Revenue Service has recently released final versions of the form and instructions for filing country-by-country (CbC) reports. Parent entities of U.S. multinational enterprise (MNE) groups with $850 million or more of revenue in a

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France: list of cooperating jurisdictions on CbC reporting requirement published

16 July, 2017

A list of jurisdictions that have introduced Country-by-Country reporting requirements and have concluded a competent authority agreement on the automatic exchange of CbC reports with France was published in the French Official Journal on 8 July

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Slovenia publishes detailed rules on CbC reporting

16 July, 2017

The Slovenian government on 16 June 2017 published the regulation on country-by-country (CbC) reporting in the Official Gazette (No. 30/2017) which came into force on 29 June 2017. The Regulation provides a more detailed description of the rules on

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Singapore: draft transfer pricing legislation proposed

15 July, 2017

According to the draft Income Tax (Amendment) Bill 2017 (Draft Bill) proposed on 19 June 2017, section 34D of the Singapore Income Tax Act (SITA) would be expanded to provide clarification on the meaning of arm’s-length conditions. The proposed

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Romania: Country-by country reporting requirements implemented

12 July, 2017

The Romanian Government passed Emergency Ordinance no. 42/2017 on 9 June 2017 to implement country-by-country (CbC) reporting requirements in Romania, transposing the provisions of Directive (EU) 2016/881 dated 25 May 2016 into the national

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Sri Lanka: New law to revise TP penalties

10 July, 2017

According to new tax law Sri Lanka, corporate that violate transfer pricing (TP) rules can be fined up to 2% of the total amount of transactions between related parties. The new law also contains the provision to impose a penalty of up to 1% of the

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South Africa: SARS issues country by country reporting, master file and local file guidance

03 July, 2017

On 23 June 2017, the South African Revenue Service (SARS) released an external Business Requirements Specification (BRS) document concerning Country-by-Country and Financial Data reporting. The document contains the draft public notice requiring the

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US: IRS Launches CbC reporting pages on IRS.gov

02 July, 2017

The Internal Revenue Service on 30 June 2017 announced the launch of Country-by-Country Reporting pages on irs.gov. These pages provide background information on Country-by-Country Reporting, frequently asked questions and other helpful resources,

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Portugal: CbC reporting deadline extended

13 June, 2017

The State Secretary for Fiscal Affairs of Portugal published “Dispatch No. 170/2017/XXI” on 29 May 2017, which has extended the deadline for country-by-country (“CbC”) reporting notifications for fiscal year 2016 further to 31 October

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Pakistan: Proposes documentation and CbC reporting requirements

12 June, 2017

On June 5, 2017, Pakistan's Federal Board of Revenue has presented a notification (Notification SRO 421 (I) / 2017) regarding Documentation and country-by-country reporting requirements in respect of transfer pricing. The proposed requirements are

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Turkey signs CRS Multilateral Competent Authority Agreement

11 June, 2017

Turkey has signed Common Reporting Multilateral Competent Authority Agreement (CRS MCAA) for the implementation of automatic exchange of financial account information pursuant to the OECD/G20 Common Reporting Standard (CRS) to launch exchanges in

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Netherlands: Bill on country-by-country reporting gazetted

10 June, 2017

The lower house of the Dutch parliament adopted a bill implementing EU directive 2016/881, mandating the automatic exchange of country-by-country reporting information among EU member states on 26th April 2017. On 2nd June 2017, EU directive

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Romania: Country-by-Country reporting requirement modified

08 June, 2017

The Romanian Ministry of Finance published a draft law on 24 May 2017 to modify the CbC reporting legislation of the country. According to the draft law, all Romanian tax resident entities which are ultimate parent of an MNE Group with annual

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South Africa and U.S. sign an agreement on the exchange of country-by-country reports

07 June, 2017

The competent authorities of South Africa and the U.S. have concluded an arrangement on the exchange of Country-by-Country Reports. On June 5, 2017 the South African Revenue Service (SARS) released the text of the arrangement. According to SARS the

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Turkey: Council of Minister proposes transfer pricing provisions

06 June, 2017

A draft Communique regarding transfer pricing has been published in Turkey. It generally represents measures of the OECD’s base erosion and profit shifting (BEPS) Action 13 on country-by-country reporting and transfer pricing documentation. The

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Lithuania: Parliament approves CbC reporting requirements

01 June, 2017

The Lithuanian Parliament on 23 May 2017, passed amendments to the Tax Administration Law to implement the CbC reporting requirements that will take effect from 5 June 2017. According to law, all Lithuanian tax resident entities that are part of an

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Brazil: Additional guidance on CbC reporting rules issued

27 May, 2017

Normative Ruling 1,709/2017 of 25 May 2017 amended the 2016 normative ruling that introduced the country-by-country (CbC) reporting obligation in Brazil effective from fiscal year(FY) 2016. According to the new ruling for FY 2016, the Brazilian tax

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