Australia: New transfer pricing documentation standards
On 6 August 2015, the Australian Treasury released exposure draft law to implement reporting requirements for large multinational businesses in line with recommendations by the OECD and G20. In the 2015-16 Budget, the Australian government announced
See MoreUS Treasury to develop regulations implementing CbC reporting requirement
US Treasury announced on 31 July 2015 that the US government intends to develop regulations implementing the OECD/G20 base erosion and profit shifting (BEPS) action plan guidance on country-by-country (CbC) reporting by multinational
See MoreUkraine: State Fiscal Service published letter regarding tax control over transfer pricing
The State Fiscal Service (SFS) published Letter No. 24525/7/99-99-22-01-02-17 issued on 7 July 2015 addressing the penalties levied for failure to submit transfer pricing (TP) documentation or to include relevant information about controlled
See MoreSpain: BEPS country by country reporting provisions enacted
The Spanish Ministry of Finance published Royal Decree 634/2015 of 10 July 2015 in the Official Gazette on 11 July, 2015. The Decree contains corporate income tax regulations including (BEPS) country by country reporting requirements in line
See MoreGreece: tax authorities issue circular to clarify transfer pricing regulations
The Greek tax authorities issued circular no. POL 1142/02.07.2015 dated July 2, 2015 to explain transfer pricing (TP) documentation issues raised in light of the new Income Tax Law no. L. 4172/2013 and Tax Procedures Code no. L. 4174/2013. The
See MoreGermany plans to adopt BEPS guidance on transfer pricing documentation and CbC reporting requirement
The German government has announced plans to incorporate guidance on transfer pricing documentation and country-by-country (CbC) reporting) in line with the OECD’s Base Erosion and Profit Shifting (BEPS) project into local legislation. The
See MorePoland: Published revised draft bill on transfer pricing documentation
Poland’s Government published the revised draft of the Personal Income Tax /Corporate Income Tax Act (Bill) concerning documentation of intercompany transactions on 18 June 2015. According to the revised draft, the management or control
See MoreBangladesh: Changes in Transfer Pricing Provisions in Finance Bill 2015 Passed by Parliament
The Bangladesh Parliament passed the Finance Bill 2015 on June 29, 2015 with some changes in the transfer pricing provisions. The legislation relating to the report from an accountant required to be furnished by a person who has entered into
See MoreSlovak Republic: New transfer pricing documentation guidance
The Finance Ministry has issued new guidance on transfer pricing documentation. This guidance creates three categories of documentation based on the degree of detail of the information required in relation to a taxpayer’s risk profile. The
See MoreThailand: Draft Act contains new transfer pricing provisions
The Cabinet of Thailand approved a draft Act on Revenue Code Amendment on 7 May 2015. If enacted the Act would introduce specific transfer pricing provisions into the Revenue Code and also would amend the tax law of Thailand to apply transfer
See MorePoland: Draft Regulation Introducing Amendments Based on BEPS Documentation Requirements
The Polish Ministry of Finance published a draft regulation on 27 April 2015 which introduced amendments on transfer pricing documentation in line with the requirements of the OECD/G20 action plan on base erosion and profit shifting
See MoreAustralia: Budget for 2015-2016 Includes BEPS Measures and Exposure Drafts for a New Targeted Anti-Avoidance Rule
The Government of Australia announced the 2015-2016 fiscal budget on May 12, 2015. Australia has included in the budget a country-by-country reporting requirement following the recommendation in the OECD/G20 action plan on base erosion and profit
See MoreUS: The Department of Treasury announces plans to implement country-by-country (CbC) reporting
The US Treasury Department has announced plans to implement a country-by-country (CbC) reporting requirement starting for fiscal years beginning in 2016 as set out in the guidance issued by the Organization for Economic Cooperation and Development
See MoreUK: draft legislation on country by country reporting
The UK Finance Bill 2015 that will be published soon after the budget announcements of 18 March 2015 is to contain legislation in respect of country by country reporting for purposes of transfer pricing documentation. The UK is committed to being
See MoreNigeria: Penalty and interest rates for unpaid tax has approved
The Federal Inland Revenue Service (FIRS) has released the accepted penalty and interest rates to be applied for the year 2015 on 2nd February 2015 regarding taxes not paid within the given periods. The 15% interest rate is determined while the
See MoreSpain: Modifies the transfer pricing legislation
In the “Corporate Income Tax Reform 2015” enacted under the Law 27/2014 the following transfer pricing rules are amended; Scope of related-party transactions - The ownership requirement for related parties is increased from 5% (1% in the
See MoreSpain: Government Announces New Country-by-Country Reporting Obligations for MNEs
The Spanish government on 20 January 2015 announced that it will issue regulations, expected to be adopted in the first half of 2015, that will require country-by-country reporting by multinationals. The new regulations would enter into force on 1
See MoreFrance: Increases Transfer Pricing Documentation Penalties
France’s 2015 Finance Bill, enacted on December 29, 2014, increased the penalties applicable in cases of failure to comply with the French transfer pricing documentation rules. The newly defined penalty for a failure to produce transfer pricing
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