U.S. and Indonesia sign an agreement on the exchange of CbC reports
According to an IRS announcement on its website, the competent authorities of the U.S. and Indonesia have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of
See MoreAustralia: New guidelines for Local and Master file for 2018
The Australian Taxation Office (ATO) has published Local file instructions 2018 and Local file/master file 2018 to provide guidance for taxpayers to comply. The local file must be electronically lodged in the approved form (an XML file generated
See MorePeru: Tax administration issues resolution regarding master file and CbC reporting requirements
The tax administration (Superintendencia Nacional de Administración Tributaria, SUNAT) issued Resolution 163-2018/SUNAT (the Resolution) on 29 June 2018 which was published in the Official Gazette. The Resolution sets out the rules for preparing
See MoreAustralia: ATO publishes draft guidance on transfer pricing issues
The Australian Taxation Office (ATO) has issued Draft Schedule 2 to Practical Compliance Guideline (PCG) 2017/1 ATO compliance approach to transfer pricing issues related to centralized operating models involving procurement, marketing, sales and
See MoreIndia: CBDT publishes guidance on appropriate use of CbC reports
On 27 June 2018, the central board of direct taxes (CBDT) released Instruction No. 02/2018 to provide guidance on the appropriate use of CbC (Country-by-Country reports) reports. In 2015, the Organization for Economic Co-operation and Development
See MoreHong Kong: Legislative council passes the transfer pricing legislation
On 4 July 2018, the Legislative Council adopted the new transfer pricing regime ((Amendment) (No. 6) Bill 2017 (the “BEPS Bill”)). During the legislative process, some changes were made to the initial bill. Remarkable changes are the possible
See MoreTurkey: General Communiqué No. 500 has been gazetted
The General Communiqué No. 500 has published on July 6, 2018, regarding Tax Procedure Law in the Official Gazette. It was entered into force on the similar day of its publication. According to the temporary article 31 of the Tax Procedure Law (or
See MoreNigeria: Cabinet approves MCAA on financial account information
The Cabinet has approved the Multilateral Competent Authority Agreement (MCAA) On July 4, 2018, regarding the automatic exchange of Financial Account Information. It was signed on August 17, 2017. It provides exchange of information in accordance
See MoreColombia: New resolution for CbC reporting
On 21 June 2018, the Colombian National Tax Authority (DIAN) issued a draft resolution concerning the obligation to notify country-by-country (CbC) reporting responsibilities. Resident taxpayers are required to file informative transfer pricing
See MoreNigeria: FIRS Issues guidelines for CbC reporting regulations
The Federal Inland Revenue Service (FIRS) has published the guidelines of Country by Country (CbC) Reporting Regulations on July 3, 2018. These Guidelines are issued to provide guidance to the general public and in particular, Multinational
See MoreRussia publishes Order on CbC report automatic exchange
On 26 June 2018, Russia has approved the Order of the Federal Tax Service of 30 May 2018 No. MMV-7-17 / 359 regarding the States and Territories list with which Russia will automatically exchange Country-by-Country (CbC)
See MoreTransfer Pricing Brief: July 2018
Sweden Restriction on interest deduction: On 14 June 2018, the Parliament passed a bill regarding a general provision limiting the deductibility of net interest expense to 30% of earnings before interest, tax, depreciation and amortization
See MoreThailand: Government submits the draft transfer pricing law to the National Legislative Assembly
On 5 June 2018, the Government submitted the draft of law amending the Revenue Code on transfer pricing to the National Legislative Assembly for approval. The draft law clarifies that taxpayers who meet the income threshold must prepare and submit
See MoreIndia: HC decides on principles for admissibility of transfer pricing appeals
On 25 June 2018, the Karnataka High Court (HC) announced the decision in the case of Softbrands India Private Limited v. DCIT (TS-475-HC-2018(KAR)-TP). The ruling sets forth some significant principles relating to admissibility of appeals by HCs
See MoreUAE signs MLI to implement tax treaty regarding BEPS measures
The UAE Ambassador to Peru, Mohammad Yousef Al Awadi, has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS). The signing took place at the 5th plenary meeting of the
See MorePeru: President authorizes to sign the MLI
On 21 June 2018, the President of Peru authorized the Minister of Economy and Finance to sign the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting. On 7 December 2016, Peru became a member
See MoreBangladesh: Parliament passes budget for FY 2018-19
On 28 June 2018, the Parliament of Bangladesh has passed the Tk 464,573 crore national budget for 2018-19 fiscal year. Finance Minister AMA Muhith moved the Appropriations Bill, 2018 seeking a budgetary allocation of Taka 571833,82,92,000 which was
See MoreSwitzerland to exchange first country-by-country reports on multinationals
The Swiss government announced that at the end of June, the Federal Tax Administration (FTA) will for the first time send multinational groups' country-by-country reports to 35 partner states within the framework of so-called country-by-country
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