Canada: Guidance about CbC reporting
The Canada Revenue Agency (CRA) has released a Guide ‘RC4651’ on 2nd March 2017 regarding Country-By-Country Reporting (CbCR) in Canada, which is only available in electronic format. This is a new filing obligation for multinational enterprise
See MoreFinland: Ministry of Finance declares their commitment to exchange CbC reports
Finland is committed to the exchange of the country-by-country (CbC) report. On March 8, 2017, an official Gazette was published by the Ministry of Finance. The Gazette states that the government is willing to comply with the Multilateral Competent
See MoreSweden approves the new legislation on transfer pricing documentation and CbC reporting
Sweden's parliament on 1 March 2017, adopted the government’s proposal on transfer pricing documentation and country-by-country reporting. The adoption amounts to the ratification of OECD’s guidelines for transfer pricing documentation and
See MoreAustralia releases guidance on IRP agreements
The Australian Taxation Office (ATO) released guidance on providing international related-party agreements (IRPA) as part of Part B of the local file for country-by-country reporting (CbCR), on 3 March 2017. The taxpayer is required to provide
See MoreAustralia: ATO releases PCG on simplified transfer pricing record-keeping
On 22 February 2017 the Australian Taxation Office (ATO) released Practical Compliance Guideline (PCG) 2017/2 dealing with simplified transfer pricing (TP) record-keeping options and assisting taxpayers in complying with relevant tax laws. The PCG
See MoreUS: IRS publishes draft instructions for Form 8975, Country-by-Country Report
The Inland Revenue Service has published, on 23 February 2017, draft version of instructions for forms that multinational enterprise (MNE) groups are to use in filing information on a country-by-country basis. Form 8975 and Schedules A (Form 8975)
See MoreJapan introduces CbC reporting notification requirements
Recently, Japan has introduced notification requirements related to Country-by-Country Reporting (CbCR) in line with the Organization for Economic Co-operation and Development (OECD) action plan on Base Erosion and Profit Shifting (BEPS)
See MoreSouth Africa: Transfer pricing proposals in 2017 budget
The Finance Minister of South Africa on 22 February 2017 delivered the budget speech to Parliament. In his speech the Minister mentioned the government’s plan for implementing a statutory transfer pricing regime in South Africa. The government
See MoreColombia: Tax reform 2016 and Transfer Pricing Updates
In accordance with law 1819 of 2016, adopting the structural tax reform bill approved on 23 December 2016, introduces the following main changes to the transfer pricing regime. According to article 260-3 of the Tax Code (TC), as amended by the tax
See MoreIsrael: Transfer pricing amendments has been proposed
The Parliament approved the bill regarding country-by-country (CbC) reporting on 1st February 2017. It must be published in the collection of laws for becoming law. This bill will become effective as from 1st March 2017. It was submitted to the
See MoreSlovak Republic: Bill on CbC reporting approved
The Parliament approved the bill regarding country-by-country (CbC) reporting on 1st February 2017. It must be published in the Collection of Laws for becoming law. This bill will become effective as from 1st March 2017. It was submitted to the
See MoreCanada: CbC report form published
A form entitled ‘RC 4649’ and instructions for completing the country-by-country (CbC) report has been published on 3rd February 2017 by the Canada Revenue Agency (CRA) for reporting the income allocation, tax allocation and business activities
See MoreIndia: Proposes amendments to the transfer pricing regulations
Indian Finance Minister published India’s 2017-18 budget on 1 February 2017. Along with other measures, the budget has proposed following important amendments to the provisions of transfer pricing (TP) regulations of India: –A major proposal in
See More7 more countries sign tax co-operation agreement to enable BEPS Action 13
According to a press release of 27 January 2017, published by the OECD, as part of continuing efforts to boost transparency by multinational enterprises (MNEs), Gabon, Hungary, Indonesia, Lithuania, Malta, Mauritius and the Russian Federation have
See MoreAustralia releases Q&A of CbC reporting
The Australian Taxation Office (ATO) released a guidance in the form of questions and answers (Q&As) in respect of compliance with country-by-country (CbC) reporting requirements. The guidance reflects the transitional administrative practice of
See MoreMalaysia: IRBM issues rules on country-by-country reporting rules (CbCR Rules)
The Inland Revenue Board of Malaysia issued the income tax (Country-by-Country Reporting) rules (“CbCR Rules”) on 23 December 2016 which came into effect on 1 January 2017. The CbC rules apply to Malaysian-parented multinational corporate groups
See MoreMalaysia: Penalty for failure to furnish country-by-country report (CbCR)
The Finance Act 2016, which was gazetted on 16 January 2017, introduced penalty provision for failure to furnish country-by-country report. A new Section 112A of the Income Tax Act 1967 is introduced to address the implications on person who fails
See MoreSlovenia publishes CbC reporting guidelines
The Slovenian Financial Administration published a new guidance on the implementation of country-by-country (CbC) reporting on 12 January 2017. The new guidelines included in Action 13 of the OECD Action Plan on Base Erosion and Profit Shifting and
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