US: IRS now accepting CbC reports
On 11 August 2017 the US IRS in its latest bulletin of news and information on country by country (CbC) reporting advised that parent entities of U.S. multinational enterprise (MNE) groups with $850 million or more of revenues in a previous annual
See MoreGreece: Law 4484/2017 regarding TP documentation requirements publishes
The Law 4484/2017 entitled "Adaptation of Greek Legislation to the provisions of Directive (EU) 2016/881 and other provisions" was published in the Government Gazette on August 1, 2017. It harmonizes Greek legislation with the provisions of Council
See MoreBrazil publishes amended regulation on CbC reporting
Normative Instruction 1,722/2017 published in Brazil’s Official Gazette on 17th July 2017 amends Normative Instruction 1,681/2016 relating to guidance on CbC reporting. According to NI 1,722/2017, transitional provisions apply if a legal entity
See MoreMalawi: Tax authority publishes transfer pricing regulations 2017
On 3 July 2017 the Malawi revenue authority published Gazette Notice No 36 of 2017 regarding Taxation (Transfer Pricing Documentation) Regulations 2017. According to the regulation, taxpayers are required to conform to contemporaneous documentation
See MoreRussia submits draft law on automatic international exchange of tax information including documentation requirements
The Russian Government on 20 July 2017, submitted the draft bill (Bill No. 231414-7) on the automatic international exchange of tax information to the Russian State Duma. The draft bill proposes amendments to the Tax Code, which are necessary for
See MoreIndia introduces CbC reporting requirements
India has included a country-by-country (CbC) reporting requirement in section 286 of the Indian Income-tax Act, 1961, with effect from the financial year 2016-2017. The requirements are principally in line with BEPS Action 13. The first round of
See MoreIreland updates transfer pricing documentation obligations
On 3 August 2017, Irish Revenue published a Tax and Duty Manual Part 35a-01-02 dealing with Transfer Pricing Documentation Obligations. The contents of this manual were previously included in Tax Briefing 07 of
See MoreGermany publishes revised guidance on CbC reporting requirements
The Germany Federal Ministry of Finance (MoF) 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. If certain requirements are
See MoreAustralia: CbC reporting local file instructions now available
On 4 July 2017, the Australian Taxation Office (ATO) published CbC reporting local file instructions together with some guidance on the meaning of “at the same time” for the purposes of the administrative solution. It allows reducing disclosures
See MoreGreece: Draft law regarding TP documentation requirements for CbC reporting
The Parliament of Greece introduced a draft Law 4484/2017 on July 20, 2017 that amends to the Corporate Income Tax Law L.4170 / 2013 and 4474/2017. The suggested amendments contain additional transfer pricing documentation requirements corresponding
See MoreCzech Republic: Chamber of Deputies passes legislation to implement CbC reporting
The chamber of deputies approved a legislation that implements a new information exchange duty, i.e. country-by-country (CbC) reporting into Czech legislation. The legislation will be effective when all legislative and processes are done. According
See MoreGermany releases guidance on CbC reporting requirements
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
See MoreUS: IRS releases final versions of CbC form and instructions
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
See MoreFrance: list of cooperating jurisdictions on CbC reporting requirement published
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
See MoreSlovenia publishes detailed rules on CbC reporting
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
See MoreSingapore: draft transfer pricing legislation proposed
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
See MoreRomania: Country-by country reporting requirements implemented
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
See MoreSri Lanka: New law to revise TP penalties
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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