Thailand enacts Transfer pricing law
On 21 November 2018, Thailand's new transfer pricing law was enacted and published in the Official Gazette and will be effective from 1 January 2019, which was approved by the National Legislative Assembly in 27 September 2018. Tax assessment
See MoreDenmark: Court imposes fines for not providing timely submission of TP documents
On 19 November 2018, the Danish tax authority published an overview of a decision by the Copenhagen Court on whether a company acted in a grossly negligent act for failing to submit the timely submission of transfer pricing (TP) documents and should
See MoreEgypt: Ministry of Finance publishes new decree 547 outlining new updated TP guidelines
On 21 October 2018, Egyptian Ministry of Finance has issued new decree 547 providing the authority for new transfer pricing guidelines to be published. The new guidelines introduced three-tiered level of transfer pricing reports for transparency to
See MoreUruguay issues guidance of new TP documentation requirements
In October 2018, the government of Uruguay issued Decree No. 353/2018 providing regulatory guidance regarding new transfer pricing (TP) documentation requirements. The decree clarifies guidance to implement the transfer pricing documentation
See MoreBulgaria: MoF proposes new mandatory documentation rule for transfer pricing
On 5 November 2018, the Ministry of Finance (MoF) published a draft consultation, proposing new mandatory documents for transfer pricing documentation, and a penalty for failure to comply with up to 1% of the value of undocumented transactions. The
See MoreBulgaria: Parliament approves budget 2019 at first reading
On 7 November 2018, the National Assembly passed the 2019 Budget Act at first reading with 115 MPs in favor and 85 opposed. The budget proposal containing amendments to the corporate tax laws. The proposed corporate income tax amendments are
See MoreFinland: Ministry of Finance submits a bill on changes to CFC rules to Parliament
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 direct or indirect
See MorePeru: SUNAT extends deadline for submission of CbC report to March 2019
On 11 November 2018, Peruvian tax authorities (SUNAT) published Ruling No. 264-2018 SUNAT which extended the due date for submitting CbC report from November 2018 to March 2019 for fiscal year 2017. The extension applies to Peruvian taxpayers who
See MoreLatvia: Parliament adopts regulation with new requirements for transfer pricing documentation
On 25 October 2018 the Parliament approved amendments to the law ‘On taxes and duties’ which introduce in Latvia the OECD format of the transfer pricing documentation. The law was published on 14 November 2018 as the official Gazette no
See MoreArgentina: Taxpayers wait for enactment of draft decree no. 1112/2017
Government has released a draft decree No.1112/2017 for tax reform Law 27430 on December 29, 2017, but it has not officially published yet. This decree includes transfer pricing aspects, permanent establishment (PE) rules, restriction on interest
See MorePoland: Parliament passes tax reform bill for 2019 including MDR
On 26 October 2018, the upper house of the Polish Parliament (the Senate) adopted the draft bill introducing far-reaching changes to the Polish tax law, including European Union (EU) Mandatory Disclosure Rules (MDR). The main difference of the
See MoreArgentina: General Resolution 4332/2018 publishes regarding CbC reporting requirements
The Federal Administration of Public Revenues (AFIP) has published General Resolution 4332 of 8 November 2018, which includes several amendments to General Resolution 4130 regarding Country-by-Country (CbC) reporting. It enters into force from
See MoreAustralia: ATO implements the OECD hybrid mismatch rules
In the 2016–17 Budget, the Australian government announced it would implement the Organisation for Economic Cooperation and Development (OECD) hybrid mismatch and branch mismatch rules from Action Item 2 of the OECD Base Erosion and Profit
See MorePanama: MHQ companies are subject to transfer pricing regulations
Law No. 57 was published on October 24, 2018 in the Official Gazette, which amends the multinational headquarters regime (MHQ regime). It contains provisions on applying transfer pricing regulations to transactions conducted by entities with an MHQ
See MoreTransfer Pricing Brief: November 2018
Nigeria Documentation-Deadline: On 3 October 2018, Federal Inland Revenue Service published a notice granting taxpayers that they have until 31 December 2018 to satisfy all pending obligations pertaining to filing of TP declaration, making
See MoreUkraine: Draft law on implementation of BEPS provisions
On 24 October 2018, Ukraine published a draft law on the implementation of some of the recommendation of the OECD/G20 reports on Base Erosion and Profit Shifting (BEPS). The draft law was developed by the Finance Ministry and National Bank supported
See MoreIndia: CBDT signs first APA renewal
On 31 October 2018, the Central Board of Direct Taxes (CBDT) has signed a unilateral advance pricing agreement (APA) renewal. Accordingly, India reached another milestone as the first ever renewal of a unilateral APA. This renewal establishes
See MoreArgentina: AFIP publishes information regarding CbC reporting
On October 24, 2018, the tax authority (AFIP) published information regarding Country-by-Country (CbC) reporting in their website. Two information regimes are implemented in order to combat tax evasion and avoidance and the transfer of benefits to
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