Transfer Pricing Brief: June 2018
Sweden: Financial services-Restriction on interest deduction: On 3 May 2018, draft legislation has been submitted to the Swedish parliament which includes safe harbour rule and limit to interest deduction. Under the proposed rules, the
See MoreTaiwan: MoF issues notice containing a list of jurisdictions regarding CbC reports
Taiwan's Ministry of Finance has (MoF) published a Notice , dated 27 April 2018, containing a list of countries or regions with which Taiwan has an agreement for the exchange of information, but not for the effectively exchange information on
See MoreNorway: Government releases the revised budget for 2018
The government of Norway released the revised Budget for 2018, which was approved by the Norwegian Cabinet on 15th May 2018. In the revised 2018 budget, the Government is proposing an increase of NOK 130 million in funding for the development
See MoreUS: IRS publishes new guideline for filing CbC reporting
On 18 May 2018, IRS released new guidance for filing the Form 8975 submitted by U.S. multinational enterprises (MNEs). When submitting Form 8975 and Schedules A (Form 8975), filers must attach at least two Schedules A (Form 8975) to the Form 8975.
See MoreKenya publishes draft income tax bill for 2018
National Treasury of Kenya has published the Draft Income Tax Bill 2018 for public comment. The draft Bill is intended to replace the current Income Tax Act with some certain provisions. Some of the main points are condensed as follows: Corporate
See MoreLatvia: Cabinet Ministers approves a draft bill on Master and Local file
Recently, the Latvia Cabinet of Ministers has approved a draft law for the introduction of Master and Local file requirements in line with BEPS Action 13. Under the law, taxpayers resident in Latvia are required to submit Master file within 12
See MoreNetherlands publishes new transfer pricing decree
The Dutch Ministry of Finance published a new transfer pricing decree nr. 2018-6865 on 22 April 2018, which was published in the State Gazette on 11 May 2018. The Decree is in line with the outcomes of the Base Erosion and Profit Shifting (BEPS)
See MoreUS: IRS issues new advance pricing agreement (APA) template
On May 11, 2018, the IRS’s Advance Pricing and Mutual Agreement Program (APMA) issued a new template that taxpayers must use when requesting an advance pricing agreement (APA) under Rev. Proc. 2015-41, 2015-35 I.R.B. 263 (Rev. Proc. 2015-41).
See MoreCayman Islands: DITC released official guidance on the CbC reporting requirements
The Cayman Islands’ Department for International Tax Cooperation (“DITC”) released their official guidance on March 29, 2018 regarding the Country-by-Country (“CbC”) reporting requirements of entities that are resident in the Cayman
See MoreRussia approves format for CbC Reports and Notification for multinational groups
On 6 May 2018, Russia’s Federal Tax Services (FTS) issued Order No. MMV-7-17/123 and Order No. MMV-7-17/124 issued on 26 April 2018 in the Official Gazette. The orders approves the format and method of submission for Country-by-Country (CbC)
See MoreItaly issues final transfer pricing regulations on the application of the arm’s length principle
Italy issued final transfer pricing regulations on May 14 regarding the application of the arm’s length principle. The publication follows the release of a draft for public consultation in February and a consultation in May. The guidance supports
See MoreSouth Africa: SARS issues notice on penalties for non-compliance of CbC report
On 11 May 2018, the South African Revenue Service (SARS) released a notice concerning penalties which provides taxpayer fails to submit returns (CbC report, Master File, Local file) by the deadline will be subject to a fixed penalty up to ZAR 16,000
See MoreFinland: Tax administration issued guidelines on the allocation of profits to PE
On 30 April 2018, the tax administration published a guideline no.A72/200/2018 on profit distribution for a permanent establishment (PE). The guidelines clarify that, upon request, a foreign company has to specify how it has allocated profits to a
See MoreUS and Indonesia sign MOU on the exchange of CbC reports
On April 26, 2018, the Internal Revenue Service issued a Memorandum of Understanding (MOU) between the Competent Authorities of the United States (US) and Indonesia, which includes an announcement of the temporary suspension of Indonesia's secondary
See MoreAustralia: Federal Budget 2018
On 8 May 2018, the Commonwealth Treasurer, Mr. Scott Morrison, announced the Federal Budget 2018-19. Mr. Morrison said “in this year's Budget there are five things we must do to further strengthen our economy to guarantee the essentials
See MoreSweden: The Draft legislation regarding corporate tax changes submits to the parliament
On 3 May 2018, the draft law was submitted to the Swedish Parliament for the introduction of new tax rules for the corporate sector. The proposal comprises new rules on re interest deductions, financial leasing and a reduced corporate tax rate. The
See MoreRussia publishes bilateral and multilateral APA Procedure
On 3 May 2018, Russia published Decree No. 60 on the Official Gazette, which approves the procedures for the conclusion of advance pricing agreements (APAs). The Russian Finance Ministry delegated the competent authority powers with respect to
See MoreAustralia: ATO announces CbC reporting deadline for local file
The Australian Taxation Office (ATO) has released its final draft of the 2018 Message Structure Table (MST) and XML Schema for the Australian Local File (ALF) for tax year 2018. This will represent the second ALF that most taxpayers will be required
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