Poland: 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
See MoreAustralia: Taxation Ruling 2014/8 introduces by the Australian Taxation Office (ATO)
Taxation Ruling 2014/8 gives outlines on what needs to be included in the documentation if the taxpayer is to meet the standard of a "reasonably arguable position" and avoid penalties, and sets out five key questions for preparation of
See MoreFrance: Tax Administration Publishes Guidelines On The Abridged Transfer Pricing Documentation
French tax administration published guidelines on the abridged transfer pricing documentation in the Official Bulletin for Public Finances Taxes on 6 November 2014. Legal persons established in France must be submitted in the French language to the
See MoreOECD: Transfer pricing documentation – Country by Country Reporting
Action 13 of the action plan on Base Erosion and Profit Shifting (BEPS) is concerned with supplying the tax administration with sufficient information to allow them to assess transfer pricing risk. The guidance issued by the OECD in September 2014
See MoreIceland: Released draft regulation on transfer pricing documentation
The Icelandic Ministry of Finance released the draft regulation on transfer pricing on 13 October 2014. According to the draft regulation outlining detailed transfer pricing rules was released on 13 October 2014 and when finalized this will apply
See MoreSlovak Republic: New guidance regarding transfer pricing documentation has been published
The Ministry of Finance has published new guidance on the contents of transfer pricing documentation (TPD) on August 20, 2014 that requires changes for most taxpayers. This alert summarizes the transfer pricing legislative developments as well as
See MoreSingapore: IRAS invites to comments on transfer pricing documentation requirements
The Inland Revenue Authority of Singapore (“IRAS”) invited comments by 24 September 2014 on its proposed update to Section 4 of the existing Singapore Transfer Pricing Guidelines relating to the transfer pricing documentation, which was first
See MoreCzech Republic: Documentation requirement for tax payer
From 1 January 2014 Czech taxpayers must send in a separate disclosure form entitled Overview of Transactions with Related Parties at the time of filing the corporate tax return. This applies to taxpayers with foreign related party transactions in
See MoreSpain: Supreme Court rules certain provisions of the transfer pricing regulations
The Spanish Supreme Court issued its final judgment regarding challenges the constitutionality of specific provisions of the transfer pricing regulations on 14 July, 2014. The Supreme Court focused the following areas; Secondary adjustment: The
See MoreFrance- Deadline for filing additional Transfer Pricing Statement
The French Government adopted a new additional transfer pricing documentation requirement codified under Article 223 quinquies B of the French General Tax Code. According to the new rule certain taxpayers will be able to file a “reduced”
See MoreSlovak Republic: New improvements in Transfer Pricing
The Financial Directorate in Slovak Republic has issued a methodological guideline on the application of transfer pricing methods. According to the changes to the OECD Transfer Pricing Guidelines in July 2010, the amendment to the ITA has abolished
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