Australia 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.
See MoreKenya publishes draft income tax bill for 2018
National Treasury of Kenya has published the Draft Income Tax Bill 2018 for public comment. The draft Bill is intended to replace the current Income Tax Act with some certain provisions. Some of the main points are condensed as follows: Corporate
See MoreLatvia: Cabinet Ministers approves a draft bill on Master and Local file
Recently, the Latvia Cabinet of Ministers has approved a draft law for the introduction of Master and Local file requirements in line with BEPS Action 13. Under the law, taxpayers resident in Latvia are required to submit Master file within 12
See MoreNetherlands publishes new transfer pricing decree
The Dutch Ministry of Finance published a new transfer pricing decree nr. 2018-6865 on 22 April 2018, which was published in the State Gazette on 11 May 2018. The Decree is in line with the outcomes of the Base Erosion and Profit Shifting (BEPS)
See MoreUS: IRS issues new advance pricing agreement (APA) template
On May 11, 2018, the IRS’s Advance Pricing and Mutual Agreement Program (APMA) issued a new template that taxpayers must use when requesting an advance pricing agreement (APA) under Rev. Proc. 2015-41, 2015-35 I.R.B. 263 (Rev. Proc. 2015-41).
See MoreCayman Islands: DITC released official guidance on the CbC reporting requirements
The Cayman Islands’ Department for International Tax Cooperation (“DITC”) released their official guidance on March 29, 2018 regarding the Country-by-Country (“CbC”) reporting requirements of entities that are resident in the Cayman
See MoreRussia approves format for CbC Reports and Notification for multinational groups
On 6 May 2018, Russia’s Federal Tax Services (FTS) issued Order No. MMV-7-17/123 and Order No. MMV-7-17/124 issued on 26 April 2018 in the Official Gazette. The orders approves the format and method of submission for Country-by-Country (CbC)
See MoreItaly issues final transfer pricing regulations on the application of the arm’s length principle
Italy issued final transfer pricing regulations on May 14 regarding the application of the arm’s length principle. The publication follows the release of a draft for public consultation in February and a consultation in May. The guidance supports
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