France-New threshold for eligibility of abridged transfer pricing documentation
In France, a new law had been enacted on 8 November 2016 which provides for a reduced threshold for taxpayers to be eligible for filing the “abridged” transfer pricing documentation (Form 2257). The threshold as codified at Article 223 quinquies
See MoreFinland: Government published a proposal on Country-by-country reporting
The Finnish government published a proposal to implement the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) initiative on transfer pricing documentation as well as a corresponding EU directive
See MoreBulgaria: Country-by-country reporting
A bill entitled “Bill 602-1-59” has been submitted to the Bulgarian parliament. The Ministry of Finance has published a draft bill on 16th September 2016 regarding the automatic exchange of country-by-country reports (CbCR). As per the draft
See MoreSlovak Republic: Introduction to country-by-country reporting
The legislative bodies of Slovakia has issued a bill amending Act No. 442/2012 Coll. on international assistance and cooperation in tax administration that introduces the country-by-country (CbC) reporting obligation in Slovakia. The draft
See MoreSingapore: Publishes Guidance on CbC Reporting
The Inland Revenue Authority of Singapore (IRAS) has published detailed guidance on the implementation of a new country-by-country (CbC) reporting requirement in the territory on 10 October 2016, which sets out entities are obliged to report and
See MoreNorway: Published proposal on Country-by-country reporting
The Norwegian Government published its proposal for the 2017 Fiscal Budget on the domestic Country-by-Country (CbC) reporting rules in line with the OECD BEPS Action 13 recommendations to the Norwegian tax authorities. As per the proposal, all
See MoreDenmark: Publishes new executive order on country-by-country reporting
A Danish executive order No. 1133 dated 27 August 2016 was issued to provide detailed rules on notice requirements and on how the CbC report must be completed. The executive order was effective from 1 September 2016. Notification requirements: i)
See MoreUK given powers to introduce public CbC reporting
The UK Government has accepted a cross-party backbench amendment to Finance Bill 2016 which gives HM Treasury powers to introduce public country-by-country reporting. The amendment allows, but does not compel, HM Treasury to bring forward
See MoreRussia: New version of draft law on BEPS Action 13 implementation issued
The Finance Ministry has issued a new version of the draft law on 6th September 2016 regarding BEPS Action 13 implementation. The draft law proposes the following topics: BEPS related compliance: Documentation requirement: Master file: As per the
See MoreTurkey: Amendment in transfer pricing legislation
The Law No. 6728 on the amendment of certain laws for the improvement of the investment landscape has been published in the Official Gazette on 9 August 2016. This law amended certain transfer pricing provisions. Some of the provisions are given
See MoreIsrael: CbC reporting, transfer pricing documentation in budget plan
The Ministry of Finance’s budget plan for 2017-2018 has been approved by the Israeli government on 12th August 2016 that includes tax legislative measures. This budget plan covers: CbC reporting requirement: General rule: The Israeli budget plan
See MoreSouth Africa: SARS published Transfer Pricing documentation proposal for public comments
The South African tax authorities published for public comments a Draft Notice on additional Transfer Pricing record-keeping requirements. Where a person has entered into a potentially affected transaction, the aggregate of the transaction for the
See MoreLuxembourg: Government submitted draft law on CbC reporting to the Luxembourg Parliament
Recently the Luxembourg Government submitted draft law n°7031 on country by country (CbC) reporting to the Luxembourg Parliament. The draft law is in accordance with a European Union (EU) Directive of 25 May 2016 requiring all EU Member States
See MoreUruguay-Bill on adoption of CbC reporting, Master file documentation and the availability of bilateral and multilateral APAs
The Uruguay Government has submitted to Congress a tax bill including adoption of the OECD’s recommendations for Country-by-Country (CbC) reporting following the scope of information to be provided under the Base Erosion and Profit Shifting (BEPS)
See MoreCzech Republic: Announcement regarding country by country reporting
The Finance Ministry of Czech has made an announcement on 11th August 2016 that it started a public consultation on a bill which would introduce changes to the Law on International Cooperation in Tax Administration. In particular, the bill would
See MoreCanada: Country-by-country reporting legislation introduced
Following on the Organization for Economic Cooperation and Development’s (OECD) Base Erosion and Profit Sharing (BEPS) initiative, the Finance Department has released draft legislative proposals on 29th July 2016 that would implement certain
See MoreSlovak Republic: MoF publishes a guideline regarding TP documentation
The principle of transfer pricing is the pricing of goods, services and so on in related party transactions surrounded by multinational enterprises to fulfill the conditions for a self-governing business relationship or to meet the arm’s length
See MoreGreece: Bill regarding transfer pricing provisions enacted
The Greek Parliament has approved a bill of the Finance Ministry on 27th July 2016 introducing significant changes regarding the transfer pricing documentation provisions. The bill, inter alia, amended various provisions of the Greek Tax Procedure
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