Australia: Implementing the OECD Hybrid Mismatch Rules
The Australian Government announced in the 2016-17 and 2017-18 Budgets that it would implement the Organisation for Economic Co operation and Development’s (OECD) rules aimed at eliminating double non-taxation benefits from hybrid mismatch
See MoreBrazil releases Private Ruling regarding deduction of payments for certain Intra-group services
Brazil has recently released Private Ruling 1001 of 9 January 2018 regarding the deduction of certain cross-border payments to a foreign subsidiary, including strategic decision support, information management, risk management and management of the
See MoreLuxembourg publishes list of jurisdictions for exchanging CbC reports
On 20 February 2018, the Luxembourg Government published the Grand Ducal Regulation of 23 February 2018 containing the list of countries considered to exchange Country-by-Country (CbC) reports. The list includes 52 jurisdictions in respect of the
See MoreHong Kong introduces CbC reporting portal
On 5 March 2018, Hong Kong government announced that it has launched its country-by-country reporting portal. Hong Kong Ultimate Parent Entities of Reportable Groups (HK UPEs) can now file CbC Returns for accounting periods beginning between 1
See MoreMalaysia: MIRB updates the form require to collect information for TP transactions
The Malaysian tax office (MIRB) has recently updated the form used by the tax authority to gather information from certain taxpayers in connection with their cross-border transactions to conduct a transfer pricing risk assessment. Certain taxpayers
See MoreIndia: CBDT signs seven more unilateral APAs
On 1 March 2018, the Ministry of Finance issued a press release announcing that Central Board of Direct Taxes (CBDT) had signed seven further Advance Pricing Agreements (APAs) in February 2018. All seven are unilateral APAs covering the
See MoreTransfer Pricing Brief: February 2018
Malaysia: APAs-Fees: In December 2017, APA rules 2012 was amended by inserting a new Rule 23 which allows the MIRB to charge an application fee and any expenses as the Director General may determine in the course of the APA application. The APA
See MoreSingapore: Published Country-by-Country Reporting regulations
The Government of Singapore published Country-by-Country Reporting in the Singapore Government Gazette the “Income Tax Regulations 2018” on 5 February under the Income Tax Act (ITA). Country-by-Country reporting application and
See MoreItaly: Draft transfer pricing regulations and corresponding adjustments
On February 21, 2018 the Italian Ministry of Economy and Finance released its draft transfer pricing rules to comply with the Article 8-10 OECD/G20 Base Erosion and Profit Shifting (BEPS) project. The draft rules are declared in their website for
See MoreUS: IRS files pre-trial memorandum against Coca Cola in transfer pricing dispute
On 15 February 2018 the IRS filed a pre-trial memorandum against The Coca Cola Company on the grounds that the transfer pricing methods used by Coca Cola were not in compliance with the arm’s length standard under section 482. The case relates to
See MoreSingapore: IRA releases revised transfer pricing guidelines
On 23 February 2018, Inland Revenue Authority issued the fifth edition of its transfer pricing guidelines outlining the improvements to the arm’s length principle, adding new transfer pricing documentation requirements, and granting new powers of
See MoreIndia: The Tribunal considers the AMP costs to be the customs value of the transaction
The Delhi Customs Excise & Service Tax Appellate Tribunal (CESTAT) in a recent case, upheld the AMP (Advertisement, Marketing and Promotion) expenses to the transaction value declared for customs purposes. In that case, the appellant was a
See MoreNetherlands: Dutch Council of Ministers approves fiscal policy agenda
The Council of Ministers approved the fiscal policy agenda on a package to combat tax avoidance and tax evasion. The most important changes are summarized below: Corporate Income Tax (CIT) rate: According to the Agenda, the current standard Dutch
See MoreMexico modifies transfer pricing filing due dates
As a result of an amendment to Article 32-H of the Federal Tax Code (FTC) became the due date amended for submission simplified informative returns on the tax situation taxpayers who choose to file an ISSIF and do business with related parties need
See MoreSerbia joins OECD’s Inclusive Framework on BEPS
According an announcement made by OECD on 19 February 2018, Serbia joined the Inclusive Framework on BEPS. Therewith the total number of jurisdictions that have joined the Inclusive Framework on BEPS comes to 112. The inclusive framework was
See MoreLithuania: Parliament issues a draft bill for the ratification of the BEPS MLI
On 2 February 2018, the Lithuanian Parliament issued a draft bill for the ratification of the MLI (the Multilateral Convention to Implement Tax Treaty Related Measures) to Prevent Base Erosion and Profit Shifting. Lithuania submitted its MLI
See MorePoland: MoF issues guidance on preparation of transfer pricing documentation
Poland's Ministry of Finance (MoF) has published general interpretation no. DCT.8201.1.2018 regarding thresholds for the obligation to prepare transfer pricing documentation on 31st January 2018. According to general interpretation
See MorePakistan issues more draft amendments to CbC reporting requirements
On 9 February 2018, the Federal Board of Revenue (FBR) in Pakistan has published SRO no. 144(I)/2018, which provides more amendments to draft rules that establish transfer pricing documentation and country-by-country reporting rules for large
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