Malta updates guidelines on the application of the notional interest deduction (NID) rules
On 8 August 2018, the Maltese Commissioner for Revenue published update guidelines on the application of the notional interest deduction (NID) rules. Under the NID, a Malta company or partnership, including a Malta permanent establishment of a
See MoreSingapore: IRAS publishes e-tax guide on country-by-country reporting
On 7 August 2018, the Inland Revenue Authority of Singapore (IRAS) published the third edition of its e-Tax Guide concerning country-by-country reporting. The purpose of the guide is to provide information to the taxpayers regarding the obligation
See MoreFinland: Ministry of Finance officially submits its budget proposal for the year 2019
On 9 August 2018, the Ministry of Finance officially submitted its budget proposal for next year 2019. The budget introduced changes to the CFC definition and applicable exemptions, including reducing the control threshold for a company that
See MoreNigeria: Areas where CCAs may conflict with domestic law
The Government has observed almost six years of significant efforts to align its domestic tax laws and regulations with international initiatives on modernization of its tax principles and enhancement of transparency and disclosure requirements.
See MoreBelgium: Ministry of Finance publishes decree on transfer pricing documentation penalties
On 2 August 2018, the Belgian Ministry of Finance published the Royal Decree of 29 June 2018 on administrative penalties for transfer pricing documentation. Taxpayers who do not meet the reporting and registration requirements for transfer pricing
See MoreColombia issues resolution on Local file and master file submission
CbC reporting requirement-Timing: On 30 July 2018, Resolution 40 of 26 July 2018 was published in the Official Journal. Accordingly, if a constituent entity is required to submit a specific transfer pricing form (form 120), the CbCR notification
See MorePeru: Published Amendments to the Transfer Pricing Provision in the Official Gazette
Peru published the Legislative Decree No. 1369 (the Decree) on 2 August 2018 in the Official Gazette. The degree amends the transfer pricing provision of the Income Tax Law in order to be aligned with the BEPS project. The main amendments to the
See MoreJamaica: TAJ publishes practice note on final version of transfer pricing agreement
Tax Administration Jamaica (TAJ) recently published the final version of a Transfer Pricing Agreement (TPA) Practice Note. The purpose of the Practice Note is to provide taxpayers and tax officials with guidance on transfer pricing agreements in
See MoreAustralia: Improving the integrity of the thin capitalization rules
The Australian Government announced that it will implement two changes to improve the integrity of Australia’s thin capitalization rules in the 2018-19 Budget. The changes are: requiring entities to align the value of their assets for thin
See MoreSlovak Republic: President signs a Law to ratify BEPS MLI
The Slovak President, Andrej Kiska, has signed a Law on July 30, 2018, for ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). This means that Slovak Republic has completed the domestic
See MoreTransfer Pricing Brief: August 2018
Australia Rule: On 9 July 2018, ATO published draft Schedule 2 compliance guideline (PCG) 2017/1, covering ATO's compliance approach to transfer pricing issues related to centralized operational models involving procurement, marketing, sales and
See MoreFrance: Court rules transfer pricing re-assessment in determining tax on added value
French tax authorities can consider income that is not “booked” in the accounts of the taxpayer-company for purposes of determining a tax on added value (“Cotisation sur la Valeur Ajoutée”—CVAE) as held by the French Supreme Tax Court
See MorePoland releases draft law amending transfer pricing rules
On 16th July 2018, Poland has released a bill to amend the country's transfer pricing rules in line with the results of the BEPS project and the OECD transfer pricing guidelines 2017 in order to improve the taxation of large multinational companies.
See MoreFrance: Tax authority publishes transfer pricing guidelines related to BEPS compliance
On 18 July 2018, the French tax authorities published instructions regarding Master / Local file in the context of transfer pricing documentation. As per the guidelines, the new documentation requirements apply for fiscal years beginning on or
See MoreFrance ratifies MLI to implement tax treaty related measures to prevent BEPS
On 12 July 2018, France ratified the bill by way of Law No. 2018-604, as published in Official Journal No. 0160 of 13 July 2018. On 5 July 2018, the National Assembly passed the bill for the ratification of the multilateral convention to implement
See MoreSouth Africa: SARS publishes guide on mutual agreement procedures
On 25 July 2018, South African Revenue Service (SARS) released a new guide on the mutual agreement procedure (MAP) that allows competent authorities from the governments of contracting jurisdictions to interact with the intent to resolve
See MoreFrance publishes arm’s length interest rate for third quarter of fiscal year 2018
The arm’s length interest rates used in determining the deductibility of interest payments to shareholders for companies whose fiscal year ends between 30 June 2018 and 29 September 2018 has been published by France. The portion of interest
See MoreUkraine signs MLI to implement tax treaty related BEPS measures
On 23rd July 2018, Ukrainian Acting Finance Minister Oksana Markarova signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting. The minister expressed that the signing of the MLI makes
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