Russia 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
See MoreTransfer Pricing Brief: June 2019
HungaryDocumentation-Timing: On 8 May 2019, the Hungarian National Tax and Customs Administration issued a notice to remind taxpayers that they must prepare their transfer pricing documentation by 31 May 2019 if they are required to keep
See MoreNew Zealand: Inland Revenue publishes revised transfer pricing regime
On 29 April 2019, Inland Revenue published the final versions of the special reports on the new rules for base erosion and profit shifting (BEPS). The rules were enacted in the Taxation (Neutralising Base Erosion and Profit Shifting) Act 2018 on 27
See MorePhilippines: DOF submits tax reform bill to Congress
The Philippines Department of Finance (DOF) has announced on 25 April 2019 that the second package (Tax Reform for Attracting Better and High-Quality Opportunities or TRABAHO) of the Duterte administration’s Comprehensive Tax Reform Program
See MorePoland publishes law amending CbC reporting rules
On 15 April 2019, Poland published the Act of 4 April 2019 amending the Act on the exchange of tax information with other countries and certain other acts including Country-by-Country (CbC) reporting rules. Under this, if a group prepares its
See MoreBelgium Updates XML Tool and the XSD schema for Local File
The Belgian Federal Public Service (SPF) Finance has published an update version 2.1 of the XML tool and the XSD schema for the Transfer Pricing (TP) Local file (Form 275 LF), which must be used for Local files submitted via the MyMinfin platform
See MoreIndonesia: MoF publishes new guidance on MAP
On 26 April 2019, the Minister of Finance (MoF) issued a new provision on the Mutual Agreement Procedure (MAP) with Regulation No. 49 / PMK.03 / 2019 (PMK-49). PMK-49 is effective from 26 April 2019 and repeals MoF Regulation No. 240 / PMK.03 /
See MoreGreece transposes the rules of the EU Anti-Tax Avoidance Directive
On 24 April 2019, Greece published Law 4607/2019 in the Official Journal containing measures to implement certain aspects of the EU's Tax Avoidance Directive (ATAD). This includes the replacement of existing rules to bring them in line with ATAD.
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