Russia: 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
See MoreChina 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
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