Transfer Pricing Brief: March 2018
Hong Kong: CbC reporting requirement: 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
See MoreEl Salvador: Ministry of Finance publishes updated transfer pricing guidelines
On 21 March 2018, the Ministry of Finance has published the updated transfer pricing guidelines (DG-001/201). The guidelines outline the comparability analysis adjustments and adjustment information provided in the transfer pricing
See MoreThe Swiss Federal Council approves tax proposal 17
The Swiss Federal Council has adopted the dispatch on TP17 for the attention of the Federal Assembly on 21st March 2018. It wishes to quickly to improve matters for domestic and foreign companies with the proposal, also on the basis of international
See MoreIndia publishes clarification regarding requirement for furnishing CbC report
On 23 March 2018, the Government of India published clarification regarding requirement for furnishing of Country-by Country Report under Section 286(4) of Income Tax Act, 1961. The government also confirmed that where a non-parent constituent
See MoreIndonesia: 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
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