Mozambique: Council of Ministers approves first transfer pricing regulations
On December 6, 2017, the Council of Ministers has approved the first Transfer Pricing (TP) Regulations by Decree 70/2017. The Decree became in force on or after the January 1, 2018. According to Decree, one company is considered to be related to
See MorePoland-OECD: Poland submits MLI instruments of ratification
On 23rd January 2018, Poland became the fourth country to deposit its instrument of ratification for MLI (Multilateral Instrument). The MLI will enter into force once five countries have deposited instruments of ratification. On 8th November 2017
See MoreSlovak Republic: Government approves several tax amendments
The President has signed an amendment to Law No. 595/2003 Coll. on Income Tax on December 20, 2017. Some of the changes are given below: Related party transaction In accordance with the current amendment, the text of the related party definition
See MoreMalaysia signs the BEPS multilateral instrument
On 24 January 2018, Malaysia signed the OECD Multilateral Convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting (“Multilateral Instrument” or “MLI”). At the beginning of 2017, Malaysia announced its
See MoreTaiwan: MoF announces Safe harbor exemption
Taiwan's Ministry of Finance (MoF) announced a “safe harbor” exemption with respect to Master file and country-by-country (CbC) reporting On 11th December 2017. Transfer pricing guidance issued in November 2017 (and known in English as
See MoreIndonesia: CbC Reporting implementing regulations
The Director General of Taxation (the DGT) of Indonesia issued DGT Regulation 29/PJ/2017 (PER-29) concerning implementing regulations on Country-by-Country (CbC) Reporting requirements, effective as of 29 December 2017. PER-29 provides some clarity
See MoreNigeria: Government signs CbCR Regulations 2018 to follow-up MCAA
The Federal Government has signed the Income Tax Regulations or Country-by-Country Reports (CbCR), 2018. The Regulations are part of the implementation plans under Action 13 of OECD’s Base Erosion and Profit Shifting (BEPS) project. This is also
See MoreDominican Republic: DGII publishes TP reporting threshold for 2018
The General Directorate of Internal Taxes (DGII) published the Transfer pricing (TP) reporting threshold for 2018 on 19 January 2018. According to the DGII, the adjusted amount that will govern for 2018 corresponds to the sum of DOP 11,015,961.
See MoreDenmark introduces new deadline for transfer pricing documentation
On 7 December 2017 the Danish Parliament passed a new law (No. L 13) launching a deadline for preparing and submitting the transfer pricing documentation. The most important changes are: The new law requires to prepare the transfer pricing
See MoreFrance: Change in Transfer Pricing Documentation Requirements
French Parliament updated their transfer pricing documentation rules. Under the Finance Act for 2018, which was approved by the Parliament on 21 December 2017, French companies must submit the transfer pricing documentation for financial years
See MoreHong Kong: BEPS Legislation working on strengthening transfer pricing enforcement regime
Hong Kong Government proposes a bill, passed on 29th December 2017, with the goals to bring in the transfer pricing principles into a system and to execute the minimum standards released to tackle Base Erosion and Profit Shifting in Hong Kong. The
See MoreKorea Rep OF: Legislation of Tax Reform Bill 2018
On 19 December 2017, Korea passed the 2018 Tax Reform Act (the 2018 tax reform) after it was passed by the Korean National Assembly on 5 December 2017. The tax reform 2018 contains provisions in line with the BEPS Action 2 and Action 4 of the OECD.
See MoreKazakhstan: Tax Law Reforms for the year 2018
The Kazakh President, signed a series of laws on 25 December 2017 regarding taxes and other mandatory payments, introduction of tax code, law on amendments to other Acts etc. Most provisions of the new tax code and the tax amendments effects from 1
See MoreBelgium: Corporate tax reform beginning from 2020
On 29 December 2017, The Belgian corporate tax reform law was published in the official gazette contains measures that will be effective as from tax periods beginning from 1 January 2020. Corporate income tax rate reduction The corporate income tax
See MoreCroatia: Closing date of CbC report submission extends for first year
A notice regarding the submission of Country-by-Country (CbC) reports has been announced on 16 January 2017 by the Tax Administration. The authority announced that CbC reports submission deadline for the 2016 reporting fiscal year was extended to
See MoreUS: IRS releases directives on transfer pricing examinations
On 12 January 2018, the IRS Large Business and International (LB&I) division publicly released a set of five LB&I directives as guidance with respect for examinations of transfer pricing issues. Interim Instructions on Issuance of
See MoreAustralia: Final guideline on cross-border related-party financing arrangements
The Australian Taxation Office (ATO) has published the final Practical Compliance Guideline PCG 2017/4 on its compliance approach to cross-border related financing arrangements. The guidance explains how taxpayers can price related party loans to
See MoreUS: IRS updates information concerning country-by-country (CbC) reporting
On 18 January 2018, the IRS issued a release announcing updates and information regarding country-by-country (CbC) reporting requirements in the United States. Under the update list, IRS publishes new content on Country-by-Country (CbC) reporting
See More