Russia approved draft law on automatic international exchange of tax information and documentation requirements
The Russian State Duma adopted in the final reading the draft law implementing international automatic exchange of financial accounting information and transfer pricing (TP) documentation of multinational Groups of Companies on 16 November 2017.
See MorePeru: Amendments made to local file reporting requirement
The Peruvian Government issued transfer pricing (TP) regulations (Supreme Decree N° 333-2007-EF) on 17 November 2017 with detail guidance on the preparation and submission of the country-by country (CbC) report. According to amendments made to
See MoreFrance: Government publishes draft second Amendment Financing Act for 2017
On 15 November 2017, a second draft amending Finance Bill for 2017 was submitted to the French Council of Ministers and was submitted to the French Parliament. The draft law emphasized the following tax measures for the coming year. Anti-Evasion
See MoreCosta Rica: Tax administration publishes draft resolution on CbC reporting
On 26 October 2017, Costa Rica’s tax administration released a draft version of a resolution that would require multinational enterprises (MNEs) to file a country-by-country (CbC) report. According to draft resolution, all Costa Rican tax resident
See MoreUK enacts interest restriction rules
On 16 November 2017, the new corporate interest restriction rules were enacted in Finance (No.2) Act 2017 that received Royal Assent to impose an additional potential restriction on UK tax relief for finance costs, after the existing tax rules
See MoreTaiwan: MoF announces changes to the transfer pricing documentation rules
The Ministry of Finance (MoF) published the amendment of Transfer Pricing Audit Rules on 13th November 2017. The rules established three-tiered transfer pricing documentation in accordance with the OECD under the base erosion and profit shifting
See MoreRomania: Guidance published on form for country-by-country reporting
On 14 November 2017, the tax administration published guidance Order no. 3049/2017 concerning the form to be used for filing country-by-country (CbC) reports. According to Order no. 3049/2017, the “country-by-country reporting” form should be
See MoreSweden: Income of pension funds to be included in the CbC reporting
The Swedish Tax Agency on 8 November 2017, has published a clarification (No. 202 439672-17/111) on any pension funds derived by life insurance companies, foreign occupational retirement institutions and pension funds pay are to be regarded as
See MoreUS: IRS releases practice units on APAs for tangible goods transactions
On November 6, 2017, the Internal Revenue Service (IRS) released two new international Practice Units (IPUs) in connection with Advance Pricing Agreements (APAs) for inbound and outbound tangible goods transactions. The IPUs provide a summary of the
See MoreUkraine clarifies classification of transactions with a non-resident legal entity
On October 4, 2017, the State Fiscal Service (SFS) published Letter No. 1945/6 / 99-99-15-02-02-15 / IPK of September 13, 2017, which specifies the classification of transactions with a non-resident legal entity for the purpose of transfer
See MoreQatar joins BEPS inclusive framework and signs BEPS Multilateral Instrument
The Organization for Economic Co-operation and Development (OECD) made an announcement on November 14, 2017, that Qatar joined the Base Erosion and Profit Shifting (BEPS) inclusive Framework. The BEPS inclusive framework is a group of countries that
See MoreColombia: New guidance for CbC reporting
In accordance with the amendments introduced by Article 108 of Law 1819 of 2016 modified article 260-5 of the Tax Code, the Colombian national tax authority (DIAN) announced that the new conditions must be fulfilled by taxpayers who are subject to
See MoreHungary: New transfer pricing Decree on Transfer Pricing Documentation rules
On 18 October 2017, the Hungarian Ministry of National Economy (NGM) issued a decree on new Transfer Pricing Documentation rules. According to the provisions of the Decree, a group is required to prepare a master file and a local file from fiscal
See MoreSweden updates guidance on CbC reporting
The Swedish tax agency has updated their tax returns and reporting guidance on country-by-country (CbC) reporting requirements on 19 October 2017. The update provides some additional clarifications based on questions that have been received by the
See MoreTransfer Pricing Brief: October 2017
Zambia: Compliance-Corporate residence: On 29 September 2017, the Budget for 2018 was presented to the National Assembly by the Minister of Finance. The Minister proposes to revise the definition of residence for corporate tax purposes by
See MoreIndia: CBDT publishes rules for CbC reporting and Master File rule
On 1 November 2017, the Central Board of Direct Taxes (CBDT) has notified rules in respect of Country-by-Country reporting and furnishing of Master File. The significant features of the Country-By-Country Report and Master File rules are: The
See MoreBulgaria: NRA approves CbC reporting format and process
The Executive Director of the National Revenue Agency (NRA) approved the country by country reporting format and procedures on October 31, 2017, by Order No. ЗЦУ-1410. According to NRA, the ultimate parent entity, who is a resident for tax
See MoreIndia: CBDT publishes the Final Rules for CbC reporting and the furnishing of the master file
On 31 October 2017, the Central Board of Direct Taxes (CBDT) published the Final Rules for country by country (CbC) reporting and the furnishing of the master file. The Final Rule contain a few administrative changes and clarifications. However, the
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