Singapore: 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
See MoreSwitzerland: Published draft legislation on country-by-country reporting
The Swiss Federal Council published draft law with respect to Country-by-Country reporting for consultation on 13 April 2016. The draft law is based on the recommendations contained in the OECD BEPS Action Plan 13 (“Transfer Pricing Documentation
See MoreSouth Africa: SARS publishes draft regulations concerning CbC reporting standard for MNEs
The South African Revenue Service (SARS) on 11 April 2016 published draft regulations concerning a country-by-country (CbC) reporting standard for multinational enterprises. South African MNEs with annual group consolidated turnover exceeding ZAR
See MorePortugal-Budget Law for 2016 implements country-by-country reporting requirements
The Portuguese Budget Law for 2016 has been approved on 16 March 2016. The approved Budget Law implements country-by-country reporting requirements. Country-by-Country (CbC) reporting requirement will be applicable for domestic entities with
See MoreMalaysia: IRB is planning to introduce a Country-by-Country (CbC) reporting requirement
The Malaysian Inland Revenue Board announced plans to introduce a Country-by-Country reporting requirement and to update current local transfer pricing documentation requirements to include the Master File and Local File concepts, in line with
See MoreTanzanian 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
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