Saudi Arabia: General Authority of Zakat and Tax (GAZT) publishes draft transfer pricing law
On 10 December 2018, General Authority of Zakat and Tax (GAZT) released draft transfer pricing regulations (TPBy-laws) for public consultation. The regulations broadly follow international standards, including the arm’s-length principle and
See MoreBelgium extends transfer pricing documentation deadline
On 7 December 2018, the Federal Service for Finance of Belgium extended the deadline for submitting master file (275MF) and local file (275LF) from 31 December 2018 to 28 February
See MoreThailand: New Transfer Pricing Law effective from January 2019
On 21 November 2018, the Transfer Pricing Act of Thailand was published in the Royal Gazette and will be effective for accounting years beginning on or after 1 January 2019. Taxpayers with related parties, regardless of having related-party
See MoreSweden:Tax Authority declares on the relevance of the TP documentation when filing an incorrect tax return
On 3 December 2018, the tax authority issued Declaration No. 202 251680-18 / 111, on the relevance of Transfer Pricing documentation in the event of a tax surcharge for providing incorrect information. If the company has made an inaccurate task
See MoreSingapore enacts the Income Tax (Amendment) Act 2018
On 12 November 2018, Singapore enacted the Income Tax (Amendment) Act 2018. The Act(amended) implements the changes in income tax announced in the 2018 budget statement and changes in the taxes resulting from the regular review of income tax
See MoreTanzania: Government issues new Transfer Pricing Regulations 2018
On April 27, 2018,Government has published new Income Tax (Transfer Pricing) Regulations of 2018. The regulations have issued on November 2018, which replaces the Income Tax(Transfer Pricing) Regulations 2014. This provides extra requirements
See MoreBulgaria includes new CFC rule and updates interest limitation rule
On 27 November 2018, Bulgaria published a Bill on amendment and supplement to the Corporate Income Tax Act in the Official Gazette. The Bill includes a new interest limitation and controlled foreign company (CFC) rules in accordance with the EU
See MoreBelgium issues draft TP guidelines for public comments
The tax authority of Belgium has published a draft Circular on the 2017 update to the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing (TP) Guidelines. On 9 November 2018, the draft Circular was published by the Belgian
See MoreTransfer Pricing Brief: December 2018
Finland Control: On 1 November 2018, the Ministry of Finance submitted a bill to Parliament proposing changes to the CFC rules. Under the proposed rules, the control threshold setting the CFC status would be reduced from 50% to 25%, and the
See MoreMexico: SAT publishes the Miscellaneous Fiscal Resolution for 2018
On 30 November 2018, the Tax Administration Service (SAT) published in its portal the "Fourth of Modifications to the Miscellaneous Fiscal Resolution for 2018" and its annexes. Modifications to the value of operations with related parties within the
See MoreMexico publishes the Fourth Resolution of Modifications to the Miscellaneous Fiscal Resolution for 2018
On 30 November 2018, the Fourth Resolution of Modifications to the Miscellaneous Fiscal Resolution for 2018 and Annexes 1, 1-A, 3, 7, 11 and 23 were published in the Official Gazette. Among others the modification added as a criterion in terms of
See MoreQatar signs MLI to implement tax treaty regarding BEPS measures
The OECD announced on December 4, 2018, that Qatar has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS). Qatar is the 85th jurisdiction to join the treaty. This treaty
See MoreBrazil: Revenue Authority publishes new Normative Instruction regarding MAP
On November 29, 2018, the Revenue Authority published Normative Instruction No. 1846 of 28 November 2018 that covers the rules for submitting a Mutual Agreement Procedure (MAP) request, the approval of a request, and the termination process. It
See MoreBrazil: Tax tribunal publishes a decision on costs included for resale price method
On November 20, 2018, the Administrative Tribunal for Federal Tax Cases (CARF) has published Decision 1402003338 of 14 August 2018. This decision states that all the expenses regarding freight, insurance, and customs need to include when allowed by
See MoreVietnam considering amendments to rules that limit related-party interest deductions
According to recent reports, the Vietnam Ministry of Finance is considering proposed amendments to the country's interest expense deduction restriction. The Decree No. 20/2017/ND-CP, enacted 24 February 2017 (Decree 20), limits deductions
See MoreChina: CbC reporting requirement for certain outbound MNCs alleviated
China has initiated country-by-country (CbC) reporting and exchange relationships with 44 countries. China expands current exchange relationship with the UK, France, and Germany. For Chinese outbound multinational companies (MNCs), the expanded CbC
See MoreAustralia: ATO extends deadline to file CbC reports
Significant Global Entities (SGE) that have a Country-by-Country (CbC) reporting obligation for the year ended 31 December 2017 will be aware that the Local file, Master file, and CbC report are due to be lodged by 31 December 2018. However, due
See MorePoland: President signed an act including amendment of TP measures effective in 2019
On 14 November 2018, President of Poland signed an act including amendment of transfer pricing measures effective in 2019. The new laws repeal the Article 9a of the CIT Act regarding transfer pricing, which is being replaced by Chapter 1a,
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