Bulgaria: Multilateral Competent Authority Agreement signs for exchange of CbC reports
Bulgaria has signed the Multilateral Competent Authority Agreement (MCAA) on November 17, 2017 for the exchange of country by country (CbC) reports under action 15 of the OECD’s BEPS
See MoreNew Zealand: A tax bill to counter tax avoidance introduces into Parliament
On 6 December 2017, a tax bill to counter tax avoidance has been introduced into New Zealand’s Parliament by multinational companies and Minister of Revenue also published its commentary on the bill. Most provisions would enter into effect July
See MorePortugal: Country-by-country reporting form approved
Portugal’s country-by-country reporting Form 54 has been approved by Order No. 367/2017 on11 December 2017. The form must be submitted electronically every year in respect of fiscal periods starting as from 1 January 2016 within 5 months after the
See MoreFrance: Country-by-country reporting
On 5 December 207, the French tax authorities released a new rule regarding the country-by-country (CbC) reporting obligations provided for by article 223 quinquies C of the French General Tax Code. According to OECD guideline jurisdictions
See MoreItaly: CbC reporting requirements
The Italian Tax Authorities (ITA) issued a Protocol No. 275956 of 28 November 2017, regarding the change in the CBC reporting requirements. The Protocol instructs further implementation rules regarding the Law 208 issued on 28 December
See MoreDenmark announces deadline for preparation of transfer pricing documentation
The Danish Parliament legislated a Bill (No. L 13) on 7 December 2017. The Bill announced a deadline for the preparation of Danish transfer pricing documentation. According to the bill, Danish taxpayers are required to prepare transfer pricing
See MoreRussia: FTS publishes CbC reporting formats for public consultation
The Federal Tax Service (FTS) publishes country-specific reporting (CbC) formats and a report on participation in multinational enterprise groups on its official website. The new forms comply with BEPS Action 13 requirements for CbC and transfer
See MoreCanada: Deadline for filing of the CbC report
According to subsection 233.8(6) of the Act, the Country-by Country (CbC) report must generally be submitted with the CRA no later than 12 months after the last day of the fiscal year to which the report relates. That means, a CbC report for the
See MoreRussia publishes final law on automatic exchange of tax information and documentation requirements
Recently, the Federal Law No. 340-FZ of 27 November 2017, amending the Tax Code in relation to the implementation of the international automatic exchange of financial accounting information and transfer pricing (TP) documentation of multinational
See MoreGreece: Revenue Authority publishes guide on submission of CbC reports
The Public Revenue Authority (AADE) published a guide to frequently asked questions (FAQs) on December 15, 2017 for describing clarifications on the country-by-country (CbC) reporting. This guide explains the step by step process and obligatory
See MoreIndia clarifies position on acceptance of the MAP and bilateral APA
On 27 November 2017, the Indian Government has announced that the MAP for transfer pricing disputes and the bilateral advance pricing agreement (APA) process would be available to taxpayers even where Article 9(2) or the equivalent is not present in
See MoreTransfer Pricing Brief: November 2017
Belgium: Main corporate income tax rate: On 27 October 2017, the government has approved the corporate tax reform bill. The rate of corporate income tax will be gradually reduced to 29% in 2018, and will be further reduce to 25% in 2020. Belgium
See MoreUK: Autumn Budget Announcements 2017
The UK’s autumn budget measures were announced on 22 November 2017. Important measures affecting business are as follows: R & D Tax Relief The Research & Development Expenditure Credit (RDEC) rate available to companies claiming under
See MoreMexico releases online platform for Transfer Pricing Informative Returns
On 1 November 2017, the Mexican Tax Administration (SAT) released the online platform and digital formats for the new informative statements for taxpayers required to submit the new Transfer Pricing Informative Returns under Article 76-A of the
See MoreIrish Revenue reschedules CbC reporting deadline
On 24 November 2017, the Irish Revenue published an eBrief No. 107/17 update stating that “Due to the late availability of the Country-by-Country (CbC) Reporting filing facility, it will remain open for, and accept, CbC Reports for fiscal years
See MoreNorway publishes updated guidelines on CbC reporting
The Tax and Customs Administration issued updated guidelines for the submission of the country-by-country reporting form RF-1352 (CbC) on 17th November 2017. According to the guidelines, CbC reports must be submitted by 31st December
See MoreAustralia releases draft legislation to address hybrid mismatch
24 November 2017, Australia’s Treasurer released exposure draft legislation to address hybrid mismatch arrangements reaffirms the Turnbull Government’s continued focus on strengthening the integrity of Australia’s tax system, and stamping out
See MorePakistan: FBR publishes rules for documentation and CbC reporting requirements
On 16 November 2017, the Federal Board of Revenue (FBR) in Pakistan has published SRO 1191(1)/2017, which includes chapter VIA to the Income Tax Rules of 2002. The new Chapter (VIA) identifies the reporting entities, clarifies the reporting
See More