Transfer Pricing Brief: December 2017
Italy: CbC Reporting requirement-Timing: On December 11, the tax authority issued a Measure no. 288555 extending the due date for filing the CbC report for fiscal year 2016 from 31 December 2017 to 9 February 2018 within 60 days following the
See MoreUkraine changes in Transfer Pricing Rules from January 1, 2018
On 7 December 2017, the Ukrainian Parliament passed the Law of Ukraine "On Amendments to the Tax Code of Ukraine and Certain Laws of Ukraine on Securing Balance of Budget Revenues in 2018” No. 2245-VIII (“Law”). The law came into force on 1
See MoreItaly: Approval of 2018 Budget Bill including new tax on digital services
The main agenda of this Bill being approved by the Italian Senate was to offset differences on tax on digital services so that it can target large multinational companies like Facebook, Apple and Google providing digital services in Italy. Italy has
See MoreHungary: Deadlines of Country-by-Country reporting and notification requirements
Issues have been generating recently on filling Hungary’s CbC reporting notification on the 17T201T form. A Hungarian resident entity is not required to file the CbC notification requirement until or unless the multi-national group has a
See MoreFrance: US Multinational Groups and the French Country-by-Country reports
The United States hasn’t been yet included in the French Ministerial Order consisting of the list of states for CbCR purposes. Discussions on the authority agreement between France and USA are still going on, which has a bit of suspense running
See MoreItaly: Italian Revenue Agency taking implementing procedures for Country-by-Country Reporting (CbCR)
New law has been introduced by the Italian Revenue Agency for the execution of CbCR concerning the medium of presentation of the reports in Italy which is in the same radar with the OECD recommendations and the EU Directions. It is mainly implied on
See MoreFinland: Government proposes to align CbC reporting with EU Directive
On 19 December 2017, Bill No. 191/2017 was submitted to the parliament as a proposal to amend section 14 d of the Act on Taxation Procedure which is in line with Council Directive (EU) 2016/881 of 25 May 2016 amending Directive 2011/16/EU. The
See MoreItaly: Tax authority extends the due date for filing the CbC report
On December 11, the tax authority issued a Measure n. 288555 extending the due date for filing the CbC report for fiscal year 2016 from 31 December 2017 to 9 February 2018 within 60 days following the measure’s publication
See MoreCyprus: Government extends the deadline for submitting CbC reports for fiscal years 2016 and 2017
On 11 December 2017, the Cyprus Tax Department issued two notices with extensions of the deadline for submission of CbC reports for the fiscal years 2016 and 2017. The deadline for submission of country by country reports for fiscal year 2016 is the
See MoreArgentina: Comprehensive tax reform enacts
The Law No. 27430 or comprehensive tax reform was published on December 29, 2017 in the Official Gazette and it generally applies from January 1, 2018. This comprehensive tax reform bill has sent to Congress on December 14, 2017. The Ministry of the
See MoreRomania: National tax administration publishes electronic forms of the CbC report
On 11 December 2017, the Romanian National Tax Administration Agency published on its website the electronic forms of the CbC report and the CbC report notification templates to be used for submission by the Romanian taxpayer forms R404 and R405,
See MoreSouth Africa: SARS extends deadline for filing of Country-by-Country reports
On 8 December 2017, the South African Revenue Service (SARS) announced that it extended the Country-by-Country report, master file and local file reporting deadline to 28 February 2018 for taxpayers with an existing reporting obligation in December
See MoreColombia updates CbC reporting obligation
The Decree 2120 of 15 December 2017 clarifies the responsibility for Colombian taxpayers of notification of the filing of the Country by Country (CbC) Report and it is applicable as of fiscal year 2016 contains the information related to the global
See MoreDenmark: Tax authority publishes press release on CbC reporting
The Danish tax administration circulated a press release (No. 17-1975627) on country-by-country (CbC) reporting on 21 December 2017. The press release instructs the Danish companies (multinational group with a turnover of DKK 5.6 billion) to file a
See MoreMalta adopts new regulations concerning CbC reporting
On 6 December 2017, the Finance ministry adopted the Regulations concerning the cooperation with other countries on tax issues. It introduces the idea of "beneficial owner" who is an individual owns or controls the customer. For an entity, the
See MoreChina: New guidance of CbC reporting
On 19 December 2017, China’s tax authority issued a public notice No. 46 clarifying country-by-country (CbC) reporting matters, that illustrate certain provisions of country-by-country (CbC) reporting will not apply for the CbC report for
See MoreZambia: MoF approves amendments in transfer pricing regulation
The Minister of Finance (MoF) is set to approve changes in transfer pricing rules, including procedures for the valuation of the transfer pricing transactions between related entities and allow for taxable income adjustments and documentation
See MoreIrish Revenue extends CbC reporting deadline
Ireland’s Country-By-Country (CbC) Reporting filing obligations are contained in Section 891H of the Taxes Consolidation Act 1997 and the Taxes (Country-by-Country Reporting) Regulations 2016. The first CbC Reports are due to be filed by relevant
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