Greece: Public Revenue Authority Published Clarification on Transactions of Real Estate Companies and Comparables
Public Revenue Authority of Greece published clarification on transactions of real estate companies and comparables data. The Public Revenue Authority issued document ΔΕΑΦΒ 1136663 ΕΞ 2015/21.10.2015 to clarify that the transfer pricing
See MorePoland: The President of Republic amends rules on transfer pricing documentation
The President of Republic of Poland signed an Act amending the Corporate Income Tax (CIT) Act, the Personal Income Tax (PIT) Act on 27 October 2015. The Act initiated important changes related to transfer pricing (TP) documentation. As per the
See MoreGreece: Enacted Rules on Transfer Pricing Penalties and Issued Guidance on TP Documentation
Greece enacted changes to the applicable transfer pricing (TP) documentation rules based on Law 4337/17.10.2015 on 17 October 2015 and issues guidance. Based on the new Law 4337/17.10.2015, the following changes are introduced to the penalties
See MoreDenmark: Government publishes a proposal to introduce CbC reporting
The Danish government published a proposal on 18 September 2015 to amend the current tax law, and provide measures that would increase the Danish transfer pricing documentation requirements and include country-by-country (CbC) reporting. The
See MoreIreland: Budget 2016 announced
On 13 October 2015, the Finance Minister of Ireland announced Budget proposals for 2016 in the context of the country being the fastest growing economy in Europe for 2015, with GDP growth at 6.2%. The Minister also published a document
See MoreUK: Consultation on draft Regulations on country by country reporting
On 5 October 2015 the UK issued draft Regulations in relation to country by country reporting, along the lines of the recommendations made in the OECD action plan on base erosion and profit shifting (BEPS). The aim is to require multinational groups
See MoreAustralia introduced multinational anti-avoidance law, CbC reporting and increased penalties
The Treasurer of Australia introduced a Bill to implement the announced multinational anti-avoidance law to apply to foreign multinationals generating certain profits earned from Australia without an Australian permanent establishment;
See MoreUK: Summary of responses to penalties discussion document
On 17 September 2015 HMRC issued a summary of responses to a discussion document on penalties. The original discussion document published on 2 February 2015 put forward five principles that should be the basis for any tax penalty regime. These are
See MoreChina: SAT is Seeking Public Comments on Consultation Draft for Implementing Special Tax Adjustments
On 17 September 2015, China’s State Administration of Taxation released a consultation draft circular concerning implementation measures for special tax adjustments that would replace the existing Guoshuifa No. 2 (Circular 2). Now the SAT is
See MoreNetherlands-Publish Budget Proposal for 2016
The Dutch Ministry of Finance published its budget proposals for fiscal year 2016 on 15 September 2015. The budget proposals cover several tax law changes, including the application of the recent modifications of the European Union (EU)
See MoreThe Netherlands -Draft law implementing new transfer pricing documentation requirements
The Dutch State Secretary of Finance released a draft law providing changes to the Dutch Corporate Income Tax Act 1969 on 15 September 2015. The proposed changes involve supplementary transfer pricing documentation requirements in line with the
See MoreRomania enacts new Fiscal Procedure Code
The Romanian tax authority has published the revised Fiscal Procedure Code in the Official Gazette no. 545 dated 23 July 2015. The existing Fiscal Procedure Code is being updated by Law 207/2015 implementing new provisions with respect to tax
See MoreUkraine: Revises its Transfer Pricing Legislation
Ukraine has introduced changes to the Tax Code regarding transfer pricing. It was officially published on August 10, 2015, and came into force from August 11, 2015. As per the new law which came into force from August 11 2015, taxpayers are
See MoreUkraine: President sigend the law on amendments to transfer pricing regulations
President of Ukraine has signed the Law No. 609-VIII on 7 August 2015 regarding Amendments to the Tax Code of Ukraine (in respect of transfer pricing)" (the Law). The Law was officially published on August 10, 2015, and came into force from August
See MoreKorea: Draft law for implementing BEPS-related transfer pricing requirements
The Ministry of Strategy and Finance of South Korea has released draft legislation for amending existing provisions of Korean law. The draft legislation generally follows Action 13 of the OECD/ G20 project on base erosion and profit shifting
See MoreColombia- Tax haven transactions subject to transfer pricing regime
The National Tax Authority of Colombia published Ruling 20776 of 2015 according to which transactions carried out with tax haven jurisdictions in tax year 2014 are subject to the transfer pricing regime. According to article 260-7 of the Tax Code
See MoreEcuador-new regulations on transfer pricing documentation requirements
Recently Ecuador’s Internal Revenue Service (IRS) has issued regulations giving outlines to new transfer pricing documentation requirements. The new regulations require taxpayers to include substantial information on the economic substance of
See MoreAustralia: Stronger penalties to fight against multinational tax avoidance
The Government of Australia announced double the maximum administrative penalties that can be applied by the Commissioner of Taxation to large companies that enter into tax avoidance and profit shifting schemes. The increased penalties, under
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