Luxembourg: Parliament adopts country-by-country reporting

27 December, 2016

The Luxembourg Parliament on 13 December 2016 passed legislation implementing country- by-country (CbC) reporting requirements for Luxembourg entities that are part of a Multinational Enterprise Group (MNE Group). The new CbC reporting legislation

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Hong Kong: IRD released country-by-country reporting

27 December, 2016

The Inland Revenue Department on 22 December 2016 published on its website an announcement on country-by-country (CbC) reporting. The CbC report requires aggregate tax jurisdiction-wide information relating to the global allocation of the income,

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Singapore- Voluntary filing of CbC Reports for Singaporean tax resident MNE groups for fiscal year 2016

26 December, 2016

The Inland Revenue Authority of Singapore (IRAS) announced on 19 December 2016 that the voluntary filings for Singaporean multinational enterprise groups for financial year 2016 will be allowed and this follows the e-tax guide of the

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Spain: Tax authority announced model country-by-country reporting form

26 December, 2016

Recently the Spanish tax authorities published a communication announcing the submission of a model country-by-country (CbC) reporting form (231). The form has not yet been approved. Under the Spanish corporate income tax regulations any entity or

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Korea-Tax reform bill of 2017 enacted

26 December, 2016

Korea enacted the tax reform bill of 2017 on 20 December 2016 which was approved by the National Assembly on 2 December 2016. According to the Tax Reform of 2017 domestic merged brother-sister companies would be considered as tax free if and only

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Ukraine-Adopted amendments to Tax Code

26 December, 2016

The parliament of Ukraine adopted a draft law amending the Tax Code on 21 December 2016. According to the adopted law, costs for repairing and maintenance of non-productive fixed assets will no longer be considered as deductible expenses. Previously

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Uruguay- New transfer pricing requirements for corporations with income derived from tax-exempt activities

21 December, 2016

The Tax Authority of Uruguay issued Ruling No. 5,947 on 6 December 2016 according to which a corporation conducts business with foreign related companies with income derived from a tax-exempt activity will be subject to the transfer pricing

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Portugal- Extension of the deadline for filing Country-by-Country reporting notification

18 December, 2016

The Secretary of State for Tax Affairs’ Office of Portugal published Decree no.254/2016-XXI (dated 12 December 2016) on 15 December 2016 which extends the deadline to submit the mandatory Country-by-Country (CbCR) notification for the fiscal year

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US: IRS issued CBC draft form

18 December, 2016

The US Internal Revenue Service (IRS) has issued a draft of IRS Form 8975 (Country-by-Country Report) that will be used for country-by-country (CbC) reporting by the US persons that are the ultimate parent entity of a multinational enterprise (MNE)

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Belgium issues TP documentation forms and instructions

18 December, 2016

During June 2016, Belgium has introduced mandatory transfer pricing documentation and country-by-country (CbC) reporting requirements in accordance with Base Erosion and Profit Shifting (BEPS) Action 13 of the Organisation for Economic Co-operation

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Jersey: Country-by-country reporting announced

16 December, 2016

The Taxation Regulation 2016 of Jersey regarding Country-by-country reporting has been made on 14th December 2016 and the regulations will entry into force on 21st December 2016. It covers a country-by-country (CbC) reporting obligation for

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Ireland: CbC reporting notification deadline

15 December, 2016

On 1 January 2016, Ireland’s new Country-by-Country (CbC) reporting requirements took effect. The Irish CbC requirements require certain Irish parented groups, and in specific instances, domestic subsidiaries of foreign parented groups, to report

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France-CbC reporting requirements conflicting to constitution

14 December, 2016

The Constitutional Court provided its decision on 8 December 2016 regarding the compatibility with the constitution of the public country-by-country (CbC) reporting requirements introduced through the bill on transparency, the fight against

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Costa Rica: A discussion draft published for comments on Transfer pricing documentation guidelines

14 December, 2016

The Costa Rican Ministry of Finance published a discussion draft on 12 December 2016 on a resolution regarding guidelines on transfer pricing documentation. The requirements under the guideline set out the operations of companies within the economic

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Denmark: Issues CbC notification rules

13 December, 2016

The Danish tax authorities (SKAT) on 9 December 2016 announced that country-by-country (CbC) notifications must be submitted electronically and in a standardised format on Form 05.034. The form contains instructions both in English and Danish, and

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Norway: Country-by-country reporting under BEPS Action 13

06 December, 2016

Finance Minister of Norway published a regulation on country-by-country reporting legislation based on proposal under Action 13 of the BEPS Action Plan on 9 December 2016. . Norway’s CbC reporting regulation will be effective from beginning of the

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Brazil: Publishes proposed Country-by-Country reporting rules

05 December, 2016

The Brazilian Federal Revenue Agency on 4 November 2016, published a proposed Normative Instruction to establish country-by-country reporting (CbCR) rules in Brazil for Multinational groups where the ultimate parent company is a resident in Brazil

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Poland: Publishes new reporting requirements for taxpayers

01 December, 2016

A customized draft act on the exchange of tax information with other states dated October 7, 2016 has been released on the websites of the Polish Government Legislation Center. The Polish legislature has decided to move the regulations on CbC

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