Indonesia: New guidance on CbC reporting
On 26 March 2018, the tax authority of Indonesia published an updated guidance on Country-by-Country (CbC) reporting. The guidance includes: The general CbC reporting requirements applicable for MNE groups with consolidated gross revenue
See MoreArgentina: CbC notification deadline extends for fiscal years ending
A Resolution entitled “General Resolution 4218 of 23 March 2018” was published in the Official Gazette. This gives an extension of the established term for the Country-by-Country (CbC) information system and also the due date to submit the
See MoreKorea: Imposed limitation on expense deductions relating to hybrid financial instruments
The 2018 Tax Reform introduces a limitation on deductible expenses relating to hybrid mismatch arrangements as a commitment to implement the hybrid mismatch rules recommended by the Organisation for Economic Co-operation and Development’s. The
See MoreKorea: Increased noncompliance penalties on transfer pricing documentation requirement
Korea has increased noncompliance penalties on transfer pricing documentation requirement. Taxpayers who fail to file a Combined Report of International Transactions (CRIT) or file false information are subject to penalties of KRW10 million
See MorePoland extends the deadline for Transfer Pricing documentation
The Ministry of Finance (MoF) released the Regulation of the Minister of Finance of 14 March 2018 regarding the extension of the deadline for taxpayers to comply with certain transfer pricing documentation obligations on 15th March 2018 in the
See MoreSingapore: New transfer pricing rules
Singapore Inland Revenue Authority published transfer pricing documentation rules and transfer pricing guidelines in February 2018. The major expansions of the transfer pricing rules are as follows: The arm’s length principle is aligned with
See MoreSlovenia deposited its instrument of ratification of the MLI
The OECD announced on 22 March 2018 that the multilateral monvention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI) will first enter into force on 1 July 2018, following Slovenia’s deposit of the fifth
See MoreIndian APA accepts customs valuation as arm’s length price for transfer pricing
Recently, the Central Board of Direct Taxes (CBDT) has entered into an advance pricing agreement (APA) where the price determined by the Indian Customs authorities was accepted as arm’s length price for import transactions for transfer pricing
See MoreSpain meets most of the elements of the action 14 minimum standard
As per the third batch of peer review reports published by the OECD, Spain meets most of the elements of the Action 14 minimum standard. In the next stage of the peer review process, Spain’s efforts to address any shortcomings identified in its
See MoreNorway meets most of the elements of the action 14 minimum standard
As per the third batch of peer review reports published by the OECD, Norway meets most of the elements of the Action 14 minimum standard. In the next stage of the peer review process, Norway’s efforts to address any shortcomings identified in its
See MoreDenmark meets most of the elements of the action 14 minimum standard
As per the third batch of peer review reports published by the OECD, Denmark meets most of the elements of the Action 14 minimum standard. In the next stage of the peer review process, Denmark’s efforts to address any shortcomings identified in
See MoreSweden: Draft legislation submits to Parliament for the Ratification of the BEPS MLI
On 15 March 2018, Government submitted draft legislation to the Parliament for the Ratification of the BEPS MLI. The MLI will generally apply for a particular Swedish bilateral tax treaty after both Sweden and the other party to the treaty have
See MoreUkraine extends the list of low-tax jurisdictions
The Cabinet of Ministers of Ukraine has expanded the list of "low-tax" jurisdictions from 65 to 80 countries, adding 17 countries (Morocco, the United Arab Emirates and 15 others) and deleting two countries (French Guiana and Lesotho). The list
See MoreSerbia: Ministry of Finance updates rulebook on arm’s length interest rates for 2018
The Serbian Ministry of Finance has updated the rulebook concerning arm’s length interest rates. The Rulebook was published in the Official Gazette of Serbia No. 18/2018 dated 9 March 2018. The Rulebook contains the prescribed interest rates
See MoreIreland: Guidelines on low value intra-group services
On 15 March 2018, Irish Revenue has published an eBrief No. 037/18 regarding guidelines on transfer pricing for low value intra-group services. The purpose of Tax and Duty Manual Part 35A-01-03 is to provide guidance to taxpayers regarding
See MoreRussia approves bilateral exchange agreements for CbC reports
The Government of the Russian Federation has published Decree No. 184 of 21 February 2018, which amends Decree No. 805 of 14 August 2014 on the conclusion of agreements for the exchange of information in tax matters. The changes include the
See MoreIndia: The deadline for multinationals to submit a master file and CbC report is 31 March
The due date for multinationals in India to furnish a country-by-country (CbC) report and masterfile for the accounting year 2016-17 is 31 March 2018. The master file must be submitted on Form 3CEAA. Part A of the form is required for all
See MoreIndia: CbC reporting changes made in Finance Bill 2018 as passed by the Lok Sabha
On 14 March 2018, the lower house of parliament (Lok Sabha) has approved the Finance Bill 2018 with modifications. One of the main changes includes by the bill is changes to the country-by-country (CbC) reporting and Master file requirements. The
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