US: IRS updates information regarding country-by-country (CbC) reporting
On 25 July 2018, Internal Revenue Service (IRS) updated the information concerning country-by-country (CbC) reporting in the United States. This includes an updated jurisdiction status table showing recently signed competent authority arrangements
See MoreNew Zealand-Sweden: Deposit ratification instrument for BEPS MLI
New Zealand and Sweden deposited their ratification certificates on 27th June and 22nd June 2018, respectively for the multilateral agreement on the implementation of tax-relevant measures to prevent erosion and profit shifting (MLI). The MLI will
See MoreOECD: Inclusive Framework Issues Progress Report
The OECD’s Inclusive Framework on base erosion and profit shifting (BEPS) has issued a progress report of its activities in the year to June 2018. The report indicates that significant developments have taken place in BEPS implementation during
See MoreIndia: CBDT signs first ever substantive revision to India-UK Bilateral APA
Recently, the Central Board of Direct Taxes (CBDT) signed the first ever substantive revision to an India-U.K. Bilateral advance pricing agreement (APA) due to certain changes in the way a particular transaction was being conducted. The changes were
See MoreIreland updates CbC Report submission guideline
On 19 July 2018, Irish revenue authority published a Tax and Duty Manual Part 38-03-21 to confirm that requests for technical support in relation to Country-by-Country Reporting must be submitted to Revenue using MyEnquiries through the Revenue
See MoreNetherlands submits legislative proposal to implement ATAD postponed
The Secretary of State for Finance has forwarded Letter no. 2018-0000119097 to the Lower House of Parliament on 13th July 2018, announcing that the legislative proposal to implement the EU's Anti-Tax Avoidance (EU) Directive 2016/1164 (2016) (ATAD1)
See MoreAustria: Parliament approves Exchange of CbC Reports and Financial Account Information
On 11 July 2018, the Federal Council (upper house of parliament) of Austria adopted two declarations as approved by the National Council (lower house) on 4 July 2018. The two declarations are relating to the effective date of the multilateral
See MoreRussia: The Lower House of Parliament Approves Bill Amending Tax Administration
On 18 July 2018, the Russian lower house of parliament adopted the Bill No. 249505-7 on improving tax administration in the third and final reading. The Bill includes following measures: Eliminate transfer pricing control (audit) for domestic
See MoreNew Zealand’s taxation act regarding Neutralising Base Erosion and Profit Shifting receives royal assent
New Zealand's Taxation (Neutralising Base Erosion and Profit Shifting) Act received royal assent on 27 June 2018. The main measures of the Act are summarized as follows: CbC reporting requirement: According to the published guidance on
See MoreUS: IRS issues new transfer pricing examination guide
On 29 June 2018, Treaty and Transfer Pricing Operations (TTPO) of the Large Business and International (LB&I) division of the IRS released the Transfer Pricing Examination Process (TPEP) for use in transfer pricing examinations. Transfer Pricing
See MoreLuxembourg: Government submits a bill for ratification of the MLI to parliament
On 3 July 2018 the Luxembourg government submitted the bill for ratification of the Multilateral Instrument (“MLI”) to parliament. On 15 June 2018, the Cabinet was approved this bill for ratification of the Multilateral Instrument
See MoreLithuania ratifies multilateral convention to implement tax treaty related measures to prevent BEPS (MLI)
On 14 June 2018, Lithuania ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) by the Law No. XIII-1271, as published in the Official Gazette on 26 June 2018. This means that Lithuania has completed
See MoreIreland publishes tax and duty manual on loans applied in acquiring an interest in a company
On 16 July 2018, Irish revenue authority published a Tax and Duty Manual concerning loans applied in acquiring an interest in a company. The contents of Tax and Duty Manual Part 08-05-02 - Loans applied in acquiring an interest
See MoreCanada: CRA publishes 2017 APA Program Report
The Canada Revenue Agency (CRA) has published an annual report on its APA program since the 2001 to 2002 fiscal year. Since 2016, the annual report has been based on a calendar year, whereas the previous annual reports were based on a fiscal year.
See MoreCanada: NRA announces successful first round of CbC report exchanges
The Minister of National Revenue Agency (NRA) has announced that Canada has completed its first round of CbC report exchanges successfully. In this way, Canada has automatic access to more information and data that will allow the Canada Revenue
See MoreU.S. and Indonesia sign an agreement on the exchange of CbC reports
According to an IRS announcement on its website, the competent authorities of the U.S. and Indonesia have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of
See MoreAustralia: New guidelines for Local and Master file for 2018
The Australian Taxation Office (ATO) has published Local file instructions 2018 and Local file/master file 2018 to provide guidance for taxpayers to comply. The local file must be electronically lodged in the approved form (an XML file generated
See MorePeru: Tax administration issues resolution regarding master file and CbC reporting requirements
The tax administration (Superintendencia Nacional de Administración Tributaria, SUNAT) issued Resolution 163-2018/SUNAT (the Resolution) on 29 June 2018 which was published in the Official Gazette. The Resolution sets out the rules for preparing
See More