Spain: Tax authority announced model country-by-country reporting form
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
See MoreKorea-Tax reform bill of 2017 enacted
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
See MoreUkraine-Adopted amendments to Tax Code
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
See MoreUruguay- New transfer pricing requirements for corporations with income derived from tax-exempt activities
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
See MorePortugal- Extension of the deadline for filing Country-by-Country reporting notification
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
See MoreUS: IRS issued CBC draft form
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)
See MoreBelgium issues TP documentation forms and instructions
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
See MoreJersey: Country-by-country reporting announced
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
See MoreIreland: CbC reporting notification deadline
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
See MoreFrance-CbC reporting requirements conflicting to constitution
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
See MoreCosta Rica: A discussion draft published for comments on Transfer pricing documentation guidelines
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
See MoreDenmark: Issues CbC notification rules
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
See MoreNorway: Country-by-country reporting under BEPS Action 13
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
See MoreBrazil: Publishes proposed Country-by-Country reporting rules
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
See MorePoland: Publishes new reporting requirements for taxpayers
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
See MoreSweden: Submits proposals for the implementation of CbC reporting bill
Proposals for the implementation of country-by-country transfer pricing reporting have been submitted to Sweden's Council on Legislation alongside a draft law to transpose the updated EU Directive on administrative cooperation. According to an
See MoreColombia: Tax reform bill 2016
The comprehensive tax reform bill 2016 recently submitted by the government of Colombia to the Congress with the following corporate income tax issues: Rates: The bill proposes to unify the income tax and the Fairness Tax into a single income tax
See MoreSouth Africa: SARS finalized additional transfer pricing documentation rules
The South African Revenue Service on 28 October 2016 published a final notice regarding additional transfer pricing documentation requirements for companies with cross-border related-party transactions exceeding R100 million. Once the R100 million
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