India deposits ratification instrument for MLI
On 25 June 2019, India has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). According to Article 34, Paragraph 2 of the MLI, with
See MoreRussia: Parliament approves law on submission of CbC reports
On 7 June 2019, the Russian parliament passed Law No. 125-FZ in the Official Gazette. The Act amends Article 105.16.3 of the Tax Code on the submission of country-by-country (CbC) reports by multinationals (MNE). The amendments extend the list
See MoreAustralia provides additional 15 days for CbC statement lodgment
The Australian Taxation Office (ATO) has provided additional 15 days for the lodgment of CbC statements (Local File, Master File, CbC report) with 30 June 2019 due date because of technical issues. This additional time will apply automatically
See MorePoland publishes explanatory note addressing transfer pricing comparability analyses
On 19 June 2019, Poland Ministry of Finance published an explanatory note addressing transfer pricing comparability analyses. Accordingly, database for comparables could be selected locally, regionally, or even globally by considering
See MorePortugal approves MLI
On 21 June 2019, the Portugal's parliament approved the resolution for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). After the ratification process,
See MoreRussia proposes Transfer Pricing and MAP-related changes
The Russian Ministry of Finance has proposed some transfer pricing amendments (Draft legislation No. 720839-7) and submitted them to the State Duma for approval (preliminary examination of the draft law submitted to the State Duma). The draft law
See MoreSaudi Arabia: GAZT holds seminar to simplify the transfer pricing regulations
On 17 June 2019, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia has organized a transfer pricing seminar in Riyadh to simplify the key areas of the transfer pricing (TP) regulations published on 15 February 2019 and to address
See MoreRussia deposits ratification instrument for MLI
On 18 June 2019, the Russian Federation has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). According to the date of deposit,
See MoreColombia: DIAN publishes procedures to submit the TP return, Master file, Local file and CbC report
On 22 May 2019, the Colombian tax authority (DIAN) published regulations for the submission of the Local file and Master file, the Transfer pricing (TP) return, and the Country-by-Country (CbC) report notification corresponding to the 2018 tax year
See MoreArgentina: Tax ruling on BEPS Action 5 minimum standard
On 30 May 2019, the Argentine tax authority published General Resolution No. 4497 (GR 4497/2019) in the official gazette amending the binding ruling (as established by Article 4 of Law No. 11,683) regulations, which adapts the Argentine tax
See MoreBelgium updates EU directive on tax dispute resolution
Belgium has published the Law of 2 May 2019, which transposes Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms in the European Union. The directive lays down rules on a mechanism to resolve
See MoreArgentina: AFIP modifies transfer pricing local compliance obligations
On 10 June 2019, the Federal Administration of Public Revenues (AFIP) published General Resolution No. 4502 in the official gazette amending transfer pricing local compliance obligations. The resolution overruled some information including
See MoreNigeria: TP returns due on 30 June
It’s a reminder for the companies with a 31 December year-end required to file a transfer pricing (TP) return by 30 June 2019. Pursuant to the Transfer Pricing Regulations of 2018, existing companies with financial year-end of 31 December 2018
See MorePanama implements CbC reporting requirements
On 27 May 2019, the Ministry of Economy and Finance of Panama published Executive Decree No. 46 in the official gazette. The decree was issued regarding implementation of country-by-country (CbC) reporting with following
See MorePanama updates form for related-party transactions
In Panama, an information return (Form 930) on the transactions conducted with related parties resident abroad should be filed within six months of the close of the fiscal year. The taxpayers, whose transactions with related parties that took place
See MoreSaudi Arabia: Cabinet approves multilateral competent authority agreement on the exchange of CbC reports
On 28 May 2019, the Saudi Arabian Cabinet sanctioned the signature of the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA). Saudi Arabia presented CbC reporting requirements, including standard
See MoreArgentina modifies TP documentation requirements
On 27 May 2019, the Federal Administration of Public Revenue (AFIP) has published General Resolution 4496 (GR 4496) in the official gazette amending General Resolution 1122 (GR 1122). The resolution explains requirements, deadline, thresholds for
See MoreBulgaria: Parliament adopts amendments to TP documentation bill at first-reading
On 5 June 2019, the Bulgarian Parliament adopted at first reading amendments to the Tax and Insurance Procedure Code, which introduced the new transfer pricing (TP) documentation requirements. One of the most important changes is in relation to
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