Australia: 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
See MoreUS: IRS release guidance on country-by-country report filing process
The US Internal Revenue Service (IRS) issued Revenue Procedure 2017-23 on 19 January 2017 describing the process for filing Form 8975, Country-byCountry Report, and accompanying Schedules A, Tax Jurisdiction and Constituent Entity Information
See MoreSpain: Government approves CbC reporting form
The country-by-country (CbC) reporting form 231 approved on 30 December 2016 in an order no. HFP/1978/2016 of 28 December 2016. The CbC report must be submitted by a company resident in Spain that is the parent company of a corporate group for the
See MoreBrazil: Regulation on CbC reporting
Normative Instruction 1,681/2016 was issued in the Official Gazette on 29 December 2016 regarding annual country-by-country (CbC) reporting. According to Normative Instruction 1,681/2016: Legal entities resident in Brazil are obliged to
See MoreCanada: Final legislation on implementation of CbC reporting requirements
Bill C-29 was passed by the House of Commons on 15th December 2016. The Bill provides the final legislation to implement country-by-country (CbC) reporting. The final legislation formalizes the introduction of section 233.8 to the Income Tax Act,
See More