Australia updates MAP guidance
The Australian Taxation Office (ATO) has updated its guidance on the mutual agreement procedure (MAP) framework contained in tax treaties to resolve disputes. The new guidance represents an update on Taxation Ruling TR 2000/16 Income tax:
See MoreTransfer Pricing Brief: October 2018
Israel Priority of Methods: According to Circular 11/2018 published on 5 September 2018, in case of sales activity that is performed without significant marketing intangibles, the most appropriate transfer pricing method according to the ITA is
See MoreNigeria: FIRS issues public notice regarding deadline set for TP documentation
The Federal Inland Revenue Service (FIRS) has previously released the Income Tax (Transfer Pricing) Regulations, 2018, which replaced the Income Tax (Transfer Pricing) Regulations, 2012. The 2018 TP Regulations, which introduced supplementary
See MoreThailand: National Legislative Assembly publishes revised draft transfer pricing act
On 27 September 2018, National Legislative Assembly released the revisions to the draft Transfer Pricing Act (the draft TP Act). The revenue threshold for subject to transfer pricing documentation is THB200 million (US$6 million) per year
See MoreZambia: Finance Minister presents National Budget 2019
On 28 September 2018, Zambia’s Minister of Finance, Hon. Margaret Mwanakatwe presented the 2019 National Budget to Parliament. The time period for making transfer pricing assessment may be raised for a period exceeding 6 years but not exceeding 10
See MoreEl Salvador: DGII updates transfer pricing information return and guidelines
On 1 October 2018, the Tax Authority (General Office of Internal Revenue ) updated the new version of the “Report on Operations with Related Parties (Form F-982v4),” whose method of filing is now changed from manual filing to online filing and
See MoreQatar: MoF implements new CbC requirements through Decision No. 21 of 2018
The Ministry of Finance published a Decision No. 21 of 2018 on September 9, 2018 in the Official Gazette. This Decision implements new Country-by-Country (CbC) reporting requirement. It is effective from September 10, 2018. A CbC report contains
See MoreUS: IRS proposes to withdraw section 385 documentation regulations
On 21 September 2018, IRS published a document proposing to remove Section 385 from treasury regulation that was finalized in the last of the 2016. The regulations require multinationals that issue related-party debt to provide information to the
See MoreMultilateral Convention (MLI) signed by Saudi Arabia
Saudi Arabia signed the Multilateral Convention on 18 September 2018 to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) bringing the total number
See MoreAustralia: ATO publishes Diverted profits tax guidance
The Australian Tax Office (ATO) published the final form of the Practical Compliance Guideline (PCG) 2018/5 Diverted profits tax (DPT) and Law Companion Ruling (LCR) 2018/6 Diverted profits tax. The PCG aims to assist affected clients and their
See MoreUS: IRS issues reminders relating to Form 8975 of CbC reporting
On 18 September 2018, IRS published a release reminding MNE groups on the processes of filing country-by-country reports on Form 8975. Reminder to U.S. MNEs Filing Form 8975 with no U.S. Schedule A (Form 8975) When submitting Form 8975 and Schedules
See MoreNetherlands: Budget Proposals 2019
On 18 September 2018, the government of Netherlands presented the 2019 budget proposals to the House of Representatives. Implementation of ATAD measures The Proposals put forward legislation that introduces various EU Anti-Tax Avoidance Directive
See MoreSpain issues amending CIT return and CbC reporting forms
On 14 September 2018, Spain published Order HAC/941/2018 of 5 September 2018 in the Official Gazette. Orders modified the regulate Form 202 (split payment of Corporation Tax and Income Tax for Non-Residents permanent establishments
See MoreNigeria: FIRS publishes a public notice regarding CbC Regulations
The Federal Inland Revenue Service (FIRS) issued a public notice on September 17, 2018. This notice provides alert that income tax country-by-country (CbC) reporting regulations S.I. no. 6, 2018 entered into force with effective from January 1, 2018
See MorePeru: Added new thin Capitalization Rules and Amended Income Tax Law
Peru’s President enacted Legislative Decree 1424 on 13 September 2018, which amends the income tax law with regard to the thin capitalization rules, the indirect transfer of shares, the definition of permanent establishment (PE) and the indirect
See MorePoland updates TP reporting regime
The Polish Ministry of Finance has announced on the e-Deklaracje website interactive forms to be used as transfer pricing (TP) reports. Beginning 1 January 2017, taxpayers that transacted or engaged in other operations with related parties of a
See MoreIsrael and Lithuania both complete ratification of BEPS MLI
Israel and Lithuania have ratified a multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). This means that both countries have completed the domestic process and deposit its ratification instrument for MLI. This
See MoreSweden: Tax Authority releases updated guidance on hard-to-value intangibles
On 13 September 2018, the Swedish tax authority published an update of transfer prices guidance on intangible assets consistent with OECD's difficult-to-measure intangible assets (HTVI) guidance. The OECD HTVI Guidance offers tax authorities with a
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