Panama sign MCAA for the exchange of CbC reporting
On 24 January 2019, the tax authority of Panama signed the Multilateral Competent Agreement (MCAA) for the exchange of Country-by-Country (CbC) reports. The purpose of the CbC MCAA is to set forth rules and procedures as may be necessary for
See MoreKazakhstan: New guidelines of TP Documentation and APA
On 24 December 2018, Mr. Alikhan Smailov, the Finance Minister of Kazakhstan approved forms and procedures for filling the Master files and Local files, effective from January 01, 2019. Generally, the rules for Master file and Local file are in line
See MoreDominican Republic: DGII issues transfer pricing documentation thresholds for 2019
On 17 January 2018, Directorate General of Internal Revenue (DGII) published the Transfer pricing (TP) reporting threshold for 2019. The DGII has issued Notice 8-19, which prescribes related party transaction threshold for transfer pricing reporting
See MorePanama publishes law containing transfer pricing rules for preferential tax regimes
On 26 December 2018, Panama released the Law No.69 in the Official Gazette No.28684-B which sets out the method for calculating income earned from the “transfer or exploitation” of intellectual property assets. The law also includes provisions
See MoreFinland gazettes the law implementing the controlled foreign company (CFC) rules
On 31 December 2018, a law was published on the implementation of CFC rules in line with EU directive (EU) 2016/1164 (2016) as adopted by the parliament which is incorporated into Finnish legislation as a Law No. 1364/2018. The law introduced
See MoreColombia legislates the tax reform Bill for 2019
Colombia enacted tax reform (Law 1943-Tax Reform) on 28 December 2018. The Tax Reform makes numerous changes to the Colombian tax rules that generally apply from 1 January 2019. The tax reform includes following changes: Corporate tax: The Tax
See MoreSingapore deposits ratification instrument for MLI
On 21 December 2018, Singapore deposited its instrument of ratification of the Multilateral Agreement for the Implementation of Measures relating to the Prevention of Erosion and Profit Shifting (MLI). As of 21 December 2018, a total of 18 countries
See MoreAustralia: ATO updates guidelines of STPRK options
The Australian Taxation Office (ATO) has recently updated Practical Compliance Guideline (PCG) 2017/2 Simplified transfer pricing record-keeping (STPRK) options. The PCG outlines transaction types or activities identified as low risk for
See MoreOECD to launch Corporate Tax Statistics
The OECD announced on 11 January 2019 that a new report and dataset entitled Corporate Tax Statistics is to be published containing internationally comparable statistics and analysis relevant to the debate on tax policy. These statistics that will
See MoreRussia publishes list of foreign states for automatic exchange of CbC reports
On 25 December 2018, The Federal Tax Service of Russia published a new list of foreign states (territories), with which Russia will automatically exchange Country-by-Country (CbC) reports. Now the list includes 53 foreign countries and 4
See MoreColombia: Tax authority publishes decree regarding tax return and TP documentation deadline
On 27 December 2018, the Colombian Tax Administration (DIAN) has published Decree No.2442 specifying the deadlines for filing and payment of the tax return (declaration) for 2019 and the deadline for transfer pricing documentation, including
See MoreFrance: Parliament adopts Finance Bill for 2019
On 20 December 2018, the French Parliament approved the Finance Bill for 2019. Tax measures taken under the Finance Bill 2019: The finance bill approves interest deductibility limitation rules in effort to comply with the European Union (EU)
See MoreDenmark: Ministry of Taxation publishes bill to implement EU ATAD
On 28 December 2018, the Danish Ministry of Taxation has published a new legislation (Law No 1726) for the implementation of the measure of the EU Anti-Tax Avoidance Directive (ATAD1) and the Directive as amended (ATAD2). The measures
See MoreUS: IRS publishes proposed regulations on certain hybrid arrangements
On 20 December 2018, IRS issued proposed regulations implementing sections 245A(e) and 267A that were added with the enactment of the Tax Cuts and Jobs Act (TCJA). The proposed Regulations concern sections 245A (e) and 267A relating to hybrid
See MoreLithuania gazettes new Transfer Pricing rules for 2019
On 31 December 2018, the Lithuanian Official Gazette published an order for the transfer pricing (TP) rules. The new requirements generally reflect measures implementing recommendations under the OECD’s base erosion and profit shifting (BEPS)
See MoreItaly releases ATAD decree in line with EU Anti-Tax Avoidance Directive
On 28 December 2018, the Italian Government published, in the Official Gazette, the Legislative Decree (Decree) transposing the European Union (EU) Anti-Tax Avoidance Directive (ATAD) in the Italian legislation. The Government had previously
See MoreUruguay updates CbC Reporting requirements
On 4 January 2019, Uruguay's Directorate General of Taxation (DGI) has issued Resolution No. 94/2019 regarding submission of Country-by-Country (CbC) reports and notifications. Uruguay's CbC reporting requirements apply fiscal years beginning on 1
See MoreEstonia implements EU ATAD measures
On 28 December 2018, Estonia published the Income Tax Amendment Act in the Official Gazette, apply from 1 January 2019. The key measures of the Act provide the implementation of the EU Anti-Tax Avoidance Directive (ATAD) as urged by the European
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