Lithuania ratifies multilateral convention to implement tax treaty related measures to prevent BEPS (MLI)
On 14 June 2018, Lithuania ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) by the Law No. XIII-1271, as published in the Official Gazette on 26 June 2018. This means that Lithuania has completed
See MoreIreland publishes tax and duty manual on loans applied in acquiring an interest in a company
On 16 July 2018, Irish revenue authority published a Tax and Duty Manual concerning loans applied in acquiring an interest in a company. The contents of Tax and Duty Manual Part 08-05-02 - Loans applied in acquiring an interest
See MoreCanada: CRA publishes 2017 APA Program Report
The Canada Revenue Agency (CRA) has published an annual report on its APA program since the 2001 to 2002 fiscal year. Since 2016, the annual report has been based on a calendar year, whereas the previous annual reports were based on a fiscal year.
See MoreCanada: NRA announces successful first round of CbC report exchanges
The Minister of National Revenue Agency (NRA) has announced that Canada has completed its first round of CbC report exchanges successfully. In this way, Canada has automatic access to more information and data that will allow the Canada Revenue
See MoreU.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See MoreAustralia: ATO publishes draft guidance on transfer pricing issues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
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