Slovenia 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
See MoreSouth Africa: SARS issues country by country reporting, master file and local file guidance
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
See MoreUS: IRS Launches CbC reporting pages on IRS.gov
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,
See MorePortugal: CbC reporting deadline extended
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
See MorePakistan: Proposes documentation and CbC reporting requirements
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
See MoreTurkey signs CRS Multilateral Competent Authority Agreement
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
See MoreNetherlands: Bill on country-by-country reporting gazetted
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
See MoreRomania: Country-by-Country reporting requirement modified
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
See MoreSouth Africa and U.S. sign an agreement on the exchange of country-by-country reports
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
See MoreTurkey: Council of Minister proposes transfer pricing provisions
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
See MoreLithuania: Parliament approves CbC reporting requirements
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
See MoreBrazil: Additional guidance on CbC reporting rules issued
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
See MoreIsrael: Status updates of automatic exchange of country-by-country (CbC) reports
The Israel Tax Authority declared the signing of a multilateral agreement for the automatic exchange of country-by-country (CbC) reports and of common reporting standard (CRS) information. The Director of tax authority signed the Multilateral
See MoreIceland issues revised bill for the CbCR
Regulation no. 1166/2016 on the documentation for CbCR (Country-by-Country Reporting) has been further revised by regulation no. 245/2017 on 24 March 2017. The revised regulation is effective on or after 24 March 2017. The revision incorporates two
See MoreHungary: CbC reporting requirements adopted
Hungary released a draft law on country-by-country (CbC) reporting on 10 March 2017 which became effective 15 May 2017. As a result, Hungary fulfilled the harmonisation requirement set by Council Directive (EU) 2016/88) and implemented the
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