Greece: Public revenue Authority publishes a circular on MCAA
The Public Revenue Authority has published a Circular on June 15, 2018 regarding the lists of jurisdictions with which Greece wants implement the Multilateral Competent Authority Agreement on the exchange of Country-by-Country (CbC)
See MoreNigeria: FIRS publishes Income Tax (CbC Reporting) regulations
The Federal Inland Revenue Service (FIRS) has released the Income Tax (Country-by-Country Reporting (CbCR)) Regulations on June 19, 2018. It was published in an official gazette on January 8, 2018. This CbCR Regulations give guidelines to
See MoreUruguay: Parliament passes a bill on the Multilateral Instrument (MLI)
4 June 2018, the Uruguayan parliament passed the Bill for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Uruguay signed the MLI on 7 June 2017. The MLI will
See MoreIndia: No international transaction with related party in the absence of an agreement with the AE
Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (the Tribunal) ruled its decision on the transfer pricing (TP) case of Colgate Palmolive (India) Ltd. v. ACIT (ITA No. 6073/Mum/2014 and ITA No. 2778/Mum/2011) in favor of the taxpayer.
See MoreIndia: The expenditure specifically incurred for Indian taxpayers’ market cannot be construed to benefit the AE
On 14 May 2018, the Delhi Bench of the Income-tax Appellate Tribunal ruled its decision on the transfer pricing (TP) case of BMW India Pvt. V. ACIT (ITA No 6160 / Del. / 2014) in favor of the taxpayer. The court held that, expenses that are
See MoreBelgium issues a FAQs on MAP and APA
On 23 May 2018, the Public Federal Service (SPF) of Belgium published a document of FAQ on Mutual Agreement Procedure (MAP) and the Advance Pricing Agreement (APA) procedure. The assessee may also request that the tax due in Belgium is not invoiced
See MoreKazakhstan signs MCAA
On 12 June 2018, Kazakhstan signed the Multilateral Competent Authority Agreement (MCAA) on the automatic exchange of Country-by-Country (CbC) reports. Kazakhstan has not yet activated the CbC MCAA in accordance with OECD’s
See MoreAustralia updates international dealings schedule for 2018 tax year
The Australian Taxation Office (ATO) has released the 2018 International dealings schedule (IDS) and their instructions for 2018 tax years. The IDS must be lodged by businesses that provide a response at the trigger questions of the relevant
See MoreIreland: New guidelines on TP compliance
On May 28, Irish Tax and Customs updated Tax and Duty Manual Part 35A-01-01 to set out the government’s approach to monitoring compliance with transfer pricing legislation contained in Part 35A of the Taxes Consolidation Act 1997. The new
See MoreBangladesh: Income Tax Proposal in Fiscal Budget 2018-2019
Finance Minister Mr. AMA Muhith presented the FY2018-19 national budget to parliament on 7th June 2018. Except for a minor downward tweaking of the corporate tax rate, and some small increases in tobacco taxation and supplementary import duties, no
See MoreGermany: The CJEU decision permits deviations from the arm’s length principle
On 31 May 2018, the Court of Justice of the European Union (CJEU) issued its decision in the case of: C-382/16 Hornbach-Baumarkt that a parent company’s position as a shareholder of a non-resident company may be taken into account in
See MoreJapan: Diet passes Bill on the Multilateral Instrument (MLI)
On May 18, 2018, the Japanese legislature passed the Bill on the Multilateral Instrument (MLI). This means that Japan has completed the national process of ratifying the MLI. The next step is for Japan to deposit its instrument of ratification,
See MoreCanada: Minister tables Notice of Ways and Means Motion to implement BEPS MLI
The Finance Minister, Bill Morneau, tabled a Notice of Ways and Means Motion in the House of Commons on May 28, 2018, for formalizing the Government's intention to introduce legislation that would enact the Multilateral Convention to Implement Tax
See MoreSlovenia publishes the clarification on MAP procedure
The Ministry of Finance of the Republic of Slovenia published the clarification on the Mutual Agreement procedure (MAP) on 7 May 2018, which is set out in the MAP scheme of the Slovenian Tax Treaty Network. The clarification provides detail in the
See MoreTransfer Pricing Brief: June 2018
Sweden: Financial services-Restriction on interest deduction: On 3 May 2018, draft legislation has been submitted to the Swedish parliament which includes safe harbour rule and limit to interest deduction. Under the proposed rules, the
See MoreTaiwan: MoF issues notice containing a list of jurisdictions regarding CbC reports
Taiwan's Ministry of Finance has (MoF) published a Notice , dated 27 April 2018, containing a list of countries or regions with which Taiwan has an agreement for the exchange of information, but not for the effectively exchange information on
See MoreNorway: Government releases the revised budget for 2018
The government of Norway released the revised Budget for 2018, which was approved by the Norwegian Cabinet on 15th May 2018. In the revised 2018 budget, the Government is proposing an increase of NOK 130 million in funding for the development
See MoreUS: IRS publishes new guideline for filing CbC reporting
On 18 May 2018, IRS released new guidance for filing the Form 8975 submitted by U.S. multinational enterprises (MNEs). When submitting Form 8975 and Schedules A (Form 8975), filers must attach at least two Schedules A (Form 8975) to the Form 8975.
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