China issued new rules on TP documentation requirement
China issued Bulletin 42 to introduce a requirement for a master file for MNC group resident in China if their annual inter-company transaction amount exceeds RMB 1 billion. The master file requirement is effective from fiscal year 2016. A master
See MoreBelgium issued new rules on CbC reporting and TP documentation requirement
Belgium issued regulation to introduce a requirement for a master file and a local file for MNC group resident in Belgium if it satisfies one of the three thresholds like a sum of operational and financial income of €50 million; or a balance
See MoreKorea: Revised draft legislation on transfer pricing and country-by-country reporting
The South Korean Ministry of Strategy and Finance has recently released a draft legislation which would amend the existing provisions of Article 11 of the Korean Law which is known as the “Law for the Coordination of International Tax Affairs”
See MoreAustria: Publishes government bill of new Transfer Pricing Documentation Law
Finance (MoF) published the government bill of the European Union (EU) Tax Amendment Act 2016, including among other provisions, the new Austrian Transfer Pricing Documentation Law (TPDL). This follows the publication of the draft TPDL on 9 May 2016
See MoreJapan: Publishes guidance under new transfer pricing documentation rules
Japan's national tax agency has released guidance concerning new transfer pricing documentation rules. The guidance released on 30 June 2016 and under Japan's 2016 tax reform, amendments were made to the Japanese transfer pricing documentation
See MoreGreece: A draft bill submitted to parliament
A draft bill was submitted to the parliament on 13th July 2016 for amending unified property tax, Procedural Tax Code and transfer pricing legislation. In accordance with the draft bill, the General Secretary of Public Revenue may discharge very
See MoreBelgian Government approved new draft legislation to implement TP documentation and CbC reporting requirements
The Government of Belgium has approved new draft legislation to effectively implement CbC reporting and introduce formal transfer pricing documentation requirements in Belgium. The draft legislation is according to 3 tiered approach of Action 13 of
See MoreJapan: The penalty for failure to submit the CbC report or the Master File by the due date
Japan’s 2016 tax reform was enacted on 29 March 2016 and at the end of April 2016, the National Tax Agency posted guidance on its website to help clarify the documentation requirements within Japan. The tax reform also implements penalties for a
See MoreSingapore: Commits to implement CbCR for financial years beginning on or after 1 January 2017
The Ministry of Finance announced on 16 June 2016, that Singapore will join the inclusive framework for the global implementation of the Base erosion and profit shifting (BEPS) Project. Under this framework, all state-and non-state jurisdictions
See MoreAustralia: Electronic Local Files template finalized
Taxpayers that fail to adhere to their tax disclosure obligations like submitting local file will be exposed to administrative penalties of AUD 4,500. The Government proposes revised penalties amounting to AUD450, 000 from 1 July 2017 for failure to
See MoreGreece: Transfer pricing obligations of acquiring company in case of merger
The Public Revenue Authority has published a legal document entitled "ΔΕΑΦΒ 1086197 ΕΞ 2016" on 2nd June 2016 for providing clarifications that the acquiring company is responsible for the submission of the relevant transfer pricing
See MoreAustria: Proposes legislation on Transfer Pricing documentation and CbC reporting
The Austrian Ministry of Finance (MoF) has published draft legislation to implement the Master File in line with the new OECD standard. The legislation includes a requirement to prepare a Master file, Local file(s), and CbCR. The new requirements
See MoreGermany: Ministry of Finance introducing CbCR, Master File and Local File
The German Ministry of Finance published a draft bill on 1 June 2016 to incorporate guidance on transfer pricing documentation and country-by-country (CbC) reporting into local legislation. The draft bill required multinationals with consolidated
See MoreAustria: Publishes Transfer Pricing Documentation draft Law
The Austrian Ministry of Finance (MoF) published the draft of the European Union (EU) Tax Amendment Act 2016 on 9 May 2016. The focus of this proposal is the draft of the new Austrian Transfer Pricing Documentation Law (TPDL). The new law serves as
See MoreBelgium would introduce Cbc reporting and transfer pricing documentation requirements
A draft law that would introduce country-by-country reporting and formal transfer pricing documentation requirements at present is in the process of being finalized in Belgium. Cbc reporting Belgium has proposed draft legislation to introduce the
See MoreNorwegian Government Issued its Proposal for Implementation of Country-by-Country Reporting
The Norwegian Government has sent its draft bill on the domestic Country-by-Country (CbC) reporting rules to the Norwegian tax authorities. As per the proposal, all multinational groups with annual consolidated group revenue equal to or exceeding
See MoreSweden Proposes Implementation of BEPS 13
The Swedish Tax Agency (STA) has proposed to implement transfer pricing documentation and Country-by-Country (CbC) Reporting. As per the proposal, the Master File reporting obligations will be applicable to MNEs that have more than 250 employees and
See MoreRussia: Draft law on CbC reporting requirements issued for public consultation
The Russian Finance Ministry has issued a draft law regarding the introduction of country-by-country (CbC) reporting in Russia on 8 April 2016. The CbC reporting requirements would apply only to international groups whose aggregate revenue according
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