Canada: MLI ratification process begins
The Parliamentary Secretary on behalf of the Minister of Foreign Affairs, Matt DeCourcey, had presented the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on January 31, 2018,
See MoreCzech Republic: Proposed amendments to income tax for 2019
Recently, Finance Ministry has published the first draft copy of the amendment to the Income Tax Act for comments. These amendments are supposed to be started from year 2019. The proposed personal income tax rate of 19% is 1.1% less than the present
See MoreCzech Republic: Cabinet approves ratification of BEPS MLI
The Cabinet of Czech Republic on February 14, 2018, approved ratification of the Multilateral Instrument (MLI) to implement into bilateral tax treaties the tax treaty-related measures arising from the OECD / G20 BEPS Project to tackle base erosion
See MoreJamaica and five more countries sign MLI to implement tax treaty related BEPS measures
On 24 January 2018, the Ministers and high-level officials from Jamaica, Malaysia, Panama, Barbados, Côte d’Ivoire and Tunisia have signed the BEPS Multilateral instrument (MLI) to amend double tax treaties to bring into effect changes designed
See MoreNorway: Government publishes new guidance on MAP
The Norwegian Government published detailed taxpayer guidance on the mutual agreement procedure (MAP) framework set out in Norway’s tax treaties on 7th February 2018. It is an instrument which shall ensure that states apply the tax treaties
See MoreUkraine: SFS publishes guidance letter on definition of related parties
On 5 February 2018, the State Fiscal Service (SFS) published Guidance Letter No. 204/6/99-99-15-02-02-15/IPK of 18 January 2018 clarifying definition of related parties regarding holding ownership of a director who owns the corporate
See MoreIreland updates rates of Corporation Tax
On 12 February 2018, the Revenue department of Ireland has published an eBrief No. 019/18, amendment to Revenue Tax and Duty Manual Part 02-02-02 - The charge to and rates of Corporation Tax - has been amended as follows: To provide guidance
See MoreHong Kong: IRD gazettes law on joining multilateral tax agreement
On 2 February 2018, the Inland Revenue Department published a law in the official gazette outlining the legal framework for Hong Kong to join a multilateral tax agreement on implementing automatic exchange of information in tax matters (AEOI),
See MoreUkraine clarifies the definition of controlled transactions for transfer pricing purposes
On 19 January 2018, the State Fiscal Service (SFS) released Guidance Letter No. 119/6 / 99-99-15-02-02-15 / IPK of January 12, 2018, which defines the definition of controlled transactions for cross border transaction purposes. Under the amendments
See MoreIndia: Budget 2018 proposes rules for implementation CbC reporting requirements
On 1 February 2018, the Finance Minister presented the Union Budget 2018. The budget includes proposals to clarify rules for implementation of the country-by-country (CbC) reporting requirements. Consequently, the due date for submits the CbC
See MoreFinland: Tax administration publishes new guidance on TP documentation
On 29 January 2018, the tax administration issued the new guidance No.A129/200/2017 on transfer pricing documentation, which replaces the previous guidance of 2007. The documentation requirement is divided into a master file and a local file. The
See MoreCosta Rica: Tax administration Gazettes CbC reporting resolution
On 2 February 2018, Costa Rica published the Resolution no.DGT-R-001-2018. Resolution No.DGT-R-001-2018 requires multinationals to submit a CbC report in accordance with the OECD's recommendations for the erosion and profit shifting base (BEPS)
See MoreMalaysia: IRBM amends the APA rules and updates the MAP guidelines
Recently, the MIRB (Malaysia Inland Revenue Board) has published an amendment to the APA Rules and the updated Mutual Agreement Procedure (“MAP”) Guidelines. The APA rules referred to as the Income Tax (Advance Pricing Arrangement) Rules 2012
See MoreAustralia: Guidelines on attribution of ADI equity capital and controlled foreign entity equity
On 24 January 2018, the Australian Taxation Office (ATO) issued the Practical Compliance Guideline (PCG) 2018/1. This Guideline sets out how the ATO will administer subsection 820-300(3) of the Income Tax Assessment Act 1997 (ITAA
See MorePakistan: FBR publishes amendments to CbC reporting requirements
On 31 January 2018, the Federal Board of Revenue (FBR) in Pakistan has published SRO no. 99(I)/2018, which provides amendments to draft rules that establish transfer pricing documentation and country-by-country (CbC) reporting requirements for large
See MoreLithuania proposes new transfer pricing rules
On 15 January 2018, a draft order amending the regulations of controlled transactions was issued by the Ministry of Finance of the Republic of Lithuania (to amend the Order No. 1K-123 dated 9 April 2004). The main points in the draft order are the
See MoreTransfer Pricing Brief: January 2018
Hong Kong: CbC reporting requirement-General rule: Inland Revenue (Amendment) (No. 6) Bill 2017 published on 29 December 2017 sets out rules on transfer pricing documentation including country-by-country reporting, and contains other measures to
See MoreFrance: Requirement for Transfer Pricing Documentations being brought in
After disappearing from the draft, the Finance Bill 2018 undergoes revision of the last year’s requirements for transfer pricing documentation and brings in some additional changes to the requirements: Failure within the ambit of the
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