Serbia: National Assembly ratifies the Multilateral Instrument (MLI)
On 19 April 2018, the National Assembly approved the law for the ratification of the multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). The agreement will enable Serbia to implement international tax cooperation
See MoreFrance: Senate approves Multilateral Instrument (MLI)
On 19 April 2018, the Senate approved the multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). The agreement will enable France to implement international tax cooperation initiatives, including the automatic
See MoreFinland: Parliament adopts a bill aligned with EU Directive on Exchange of Information
On 6 April 2018, Parliament adopted a bill amending the relevant provisions of the Taxation Act in order to clarify the wording of the provisions of Council Directive (EU) 2016/881 of 25 May 2016 on administrative cooperation in the taxation of
See MoreItaly: Transfer pricing consultation responses published
On 5 April 2018, the Ministry of Economy and Finance published the responses received to the public consultation on transfer pricing legislation launched in February 2018. Comments and proposals are available on the website of the Ministry of
See MoreZambia: Government publishes new transfer pricing regulations
Zambia published the income tax (transfer pricing) (Amendment) regulations under Statutory Instrument No. 24 of 2018 in the official gazette on 6th April 2018. The 2018 regulations conduct transfer pricing transactions between related entities as
See MoreGreece: Parliament adopts draft bill regarding Multilateral Competent Authority Agreement
The Greek Parliament adopted a draft bill on April 19, 2018, which ratifies the Multilateral Competent Authority Agreement between Greece and United States on the exchange of country by country (CbC) reports. The CbC report is one element of
See MoreDenmark: Eastern High Court applies contemporaneous transfer pricing documentation rule
On 28 March 2018 a summary of a decision of the Eastern High Court in a transfer pricing case involving Microsoft Denmark was published. The case was dealt with by the Supreme Court at first instance after the court had referred it as principle. The
See MoreUK published draft order to bring BEPS MLI into Effect
UK HM Treasury has laid before the House of Commons the draft Double Taxation Relief (Base Erosion and Profit Shifting) Order 2018. After the order is approved, the UK must then deposit its ratification instrument to enter into force in the
See MoreIndia proposes changes in advance ruling forms for transparency in cross-border deals
On 10 April 2018, the central board of direct taxes (CBDT) issued a draft which includes changes to the income tax rules and forms to align them more closely with the OECD’s base erosion and profit shifting (BEPS) Action 5. The draft essentially
See MoreUS: IRS issues guidance on restriction on interest deduction
On 2 April 2018, the Treasury Department and the Internal Revenue Service (IRS) published Notice 2018-28, which provides guidance for computing the business interest expense limitation under recent tax legislation enacted on Dec. 22, 2017. In
See MoreIndonesia launches electronic system for CbC report submission
On 13 April 2018, Directorate General of Taxation of Indonesia has declared the launch of the electronic submission system for Country-by-Country (CbC) reports via the DJP Online Portal. The system provides a step-by-step guideline for the
See MoreUS: IRS offers guidance on ‘blended’ tax rates for corporations under the new tax reform law
On 16 April 2018, the Internal Revenue Service issued a notice that many U.S. corporations elect to use a fiscal year end instead of a calendar year end for federal income tax reporting purposes. Due to a provision in the recently enacted Tax Cuts
See MorePanama issues new form of transfer pricing information return
In accordance with Resolution No. 201-1937 of 2 April 2018, published in the Official Gazette on 9 April 2018, Panama modified Form No. 930 (V1.0), Transfer Pricing Information Return. The new form is Form No. 930
See MoreTaiwan: Government clarifies transfer pricing documentation thresholds
On 1st April 2018, the Taiwanese government defined how companies should calculate transfer pricing disclosure and documentation thresholds when they operate less than a full year due to fiscal year change, merger, or acquisition. According to the
See MoreCanada: CRA issues MAP program report
The Canada Revenue Agency (CRA) issued the latest mutual agreement procedure (MAP) program report on April 13, 2018. The MAP program is a service provided by the CRA to assist taxpayers in resolving cases of double taxation or taxation not in
See MoreQatar: Cabinet approves BEPS MLI
The Qatari Cabinet approved on April 11, 2018, the Multilateral Instrument (MLI) to implement into bilateral tax treaties the tax treaty-related measures arising from the OECD / G20 BEPS Project to tackle base erosion and profit shifting (BEPS). It
See MoreUS: IRS publishes annual advance pricing agreement report for 2017
On 30 March 2018 with an announcement, IRS published Advance Pricing Agreement (APA) report for the calendar year 2017. The report describes the experience, structure, and activities of the APMA Program during calendar year 2017. It does not provide
See MoreUS: IRS publishes a notice concerning CbC reporting requirements of certain U.S. MNE groups
On 30 March 2018, IRS released an advance copy of Notice 2018-31 concerning national security considerations with respect to country-by-country (CbC) reporting. In consideration of the national security interests of the United States, the notice
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