Tanzanian Requires Taxpayers with Related-Party Transactions Contemporaneous Transfer Pricing Documentation
The requirement for transfer pricing documentation has been in place since February 7, 2014 but the Tanzania Revenue Authority (TRA) had not previously enforced this requirement. TRA have started requesting transfer pricing documentation from
See MoreJapan approves tax reforms for 2016
The parliament (National Diet) on 29 March 2016 passed the tax reform for 2016. The main changes are set out below: Corporate income tax: The main corporation tax rate is to be reduced to 23.4% from 23.9% for taxable years beginning on or after 1
See MoreCanada: Proposal regarding CbC reporting in Budget 2016
Canadian Budget for 2016 proposes new legislation to strengthen transfer pricing documentation by introducing country-by-country reporting for large MNEs. The new transfer pricing documentation rules will follow the base erosion and profit shifting
See MoreTurkey: Draft communiqué on transfer pricing documentation, country-by-country reporting
The revenue administration of Turkey has issued a draft communiqué on 16th March 2016 that would introduce new transfer pricing documentation rules that generally follow the base erosion and profit shifting (BEPS) Action 13 recommendations and
See MoreIndia: Country-by-country reporting, transfer pricing documentation rules in budget 2016
The fiscal budget was announced in India on 29 February 2016. One of the most important developments from a Transfer Pricing (TP) regulations perspective was introduction of Country-by-Country (CbC) reporting norms for TP documentation. If this
See MoreUK: Introduced Country-by-Country (CbC) Reporting Requirement as Final Regulation
UK has introduced Country-by-Country (CbC) reporting requirement for domestic entities with consolidated group revenue of €750 million or more for an accounting period. The Commissioners may give a general or specific direction to a reporting
See MoreChile: IRS established an obligation to submit a new affidavit aligned with BEPS
According to tax audit strategy of Chile, the Internal Revenue Service (IRS) has improved its formal requirements for Chilean taxpayers. On 24th December 2015, the IRS established an obligation to submit an affidavit F.1913 (Annual Return of Global
See MoreNigeria: Country-by-country reporting update
A Multilateral Competent Authority Agreement (MCAA) has been signed by Nigeria for executing the exchange of country-by-country (CbC) reports. This reports will include summary of income earned and tax paid, and the number of employees positioned by
See MoreFrance-New country-by-country reporting requirement, transfer pricing declaration
The Finance Act for 2016 and the Amended Finance Act for 2015 were published in the official journal on 30 December 2015. The Finance Act for 2016 introduces a country-by-country reporting obligation in Article 223 C of the French general tax code,
See MoreFinland: Ministry of Finance publishes a proposal regarding transfer pricing documentation rules and CbC reporting requirements
The Ministry of Finance on 21 December 2015 released for public comment a proposal to revise the transfer pricing documentation rules and introduce country-by-country (CbC) reporting. The proposed legislation would follow the three-tiered approach
See MoreNorway Published a Public Consultation Paper Regarding CbC Reporting for Tax Purposes
Norway has published a public consultation paper regarding country-by country (CbC) reporting for tax purposes. As per the proposal, multinational groups when the ultimate parent company is a resident in Norway would be required to submit country-by
See MoreThe Dutch Parliament approved bill on supplementary transfer pricing documentation requirements
The Dutch Parliament approved the Other Fiscal Measures Bill that includes supplementary transfer pricing documentation requirements in order with the three tiered approach of Action 13 of the OECD Base Erosion and Profit Shifting (BEPS) project, on
See MoreSouth Africa: SARS announces to implement country-by-country reporting requirement
In line with the OECD base erosion and profit shifting (BEPS) initiative (action 13), effective 1 January 2016, South Africa Revenue Service (SARS) has announced that it will implement country-by country (CbC) reporting. The CbC report is the third
See MoreUS: Treasury and IRS Issued Proposed Regulations on Country-by-Country Reporting on 21 December 2015
The Internal Revenue Service (IRS) and the Treasury Department (Treasury) released proposed regulations (REG-109822-15) on country-by-country (CbC) reporting on 21 December 2015. The Proposed Regulations are modeled on the Organization for Economic
See MoreFrance-Approved Finance Bill 2016 and amended Finance Bill 2015
The French Parliament approved the Finance Bill for 2016 and and the amended Finance Bill for 2015 on 17 December 2015. The Finance Bill enacts the country-by-country (CbC) reporting requirement into the legislation of France. From 1 January 2016
See MoreCountry-by-country reporting is enacted in Ireland
On 22 December 2015, the president of Ireland signed into law Finance Act 2015 that includes rules following the OECD's recommended country-by-country (CbC) reporting requirements. The Finance Act provision closely mirrors the OECD’s recommended
See MoreItaly: Budget for 2016 Approved with Reduction of Corporate Tax Rate and CbC Reporting Requirement
The 2016 budget law that has now been approved includes reduction of corporate tax rate for 2017 and Country-by-Country (CbC) reporting requirements with amendments in Act n. 2111-B. The Law no. 208 of 28 December 2015 provides a reduction of the
See MoreKorea: Tax reform bill of 2016 enacted
The National Assembly of Korea passed the Tax Reform Bill of 2016 on 2 December 2015. The bill was enacted on 15 December 2015 and certain Enforcement Decrees are expected to be approved by the Government in the near future. According to the
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