US: Government signs joint statement on exchange of country-by-country tax reports with France
On January 12, the IRS announced on its website that the US and French competent authorities would like to sign a joint statement to spontaneously exchange CbC reports submitted by their respective taxpayers. The Competent Authorities desire to
See MoreHong Kong signs AEOI agreement with France
According to an announcement published on 15 January 2018, Hong Kong has signed an agreement with France on the automatic exchange of financial account information in tax matters (AEOI). The Multilateral Convention on Mutual Administrative
See MoreSweden publishes CbC reporting threshold rules
The Swedish Tax Agency published a guidance on companies' country-by-country reporting (CbC) obligations with respect to short and extended tax years, and company divestments and restructurings on 15 January 2018. The guidance provides following
See MoreJamaica: TAJ revised the income tax return forms and due date
Tax Administration Jamaica wishes to advise that the deadline to file Final Income Tax Returns forms for the year of assessment 2017 has been extended until 15 March 2018. TAJ also stated that the revisions are improvements which will allow the
See MoreEcuador reforms tax law for 2018
On 29 November 2017, Ecuador has enacted a new law published in Official Gazette-150 that reforms tax laws, effective as of 1 January 2018. Corporate income tax The new law increases the corporate income tax rate from 22% to 25% and withholding
See MoreMalaysia: IRBM updates the rules for CbC reporting
The Inland Revenue Board (IRB) has recently published an amendment to the country-by-country (CbC) rules. Among the changes, the amended CbC rules include revised measures regarding entities having cross-border transactions with other constituent
See MoreThailand: Cabinet approves draft Transfer Pricing Act
On 3 January 2018, the Thai Cabinet approved the draft transfer pricing act following a public hearing held in July 2017 on the first draft Act that was approved in principle in May 2015. Subject to a legislative procedure and announcement, the
See MoreColombia issues regulations on CbC reporting notification requirement
The tax authority of Colombia (DIAN) published Decree 2120 of 15 December 2017 concerning the obligation for taxpayers to inform the tax authorities whether they are required to file the Country-by-Country (CbC) report. The CbC report filing
See MorePortugal: Requirements for the preparation and exchange of Country-by-Country Reports published
On 21 December 2017, Portuguese Orders number 383-A/ 2017 and 383-B/2017 were published in the Official Gazette. Order number 383-A/2017 approved form 55 containing the CbC report. Form 55 must be submitted electronically on an annual basis and
See MoreSpain amends the CbC reporting rules to align with EU Directive
On 30 December 2017, Royal Decree 1074/2017 amending the corporate tax rules and other provisions was published in the Official Journal. Royal Decree 1074/2017 amends, among other things, the Spanish CbCR rules in order to better align them with EU
See MoreHong Kong publishes a bill to implement transfer pricing documentation
On 29 December 2017, Inland Revenue (Amendment) (No. 6) Bill 2017 published in order to sets out rules on transfer pricing documentation including country-by-country reporting, and contains other measures to implement the minimum standards under
See MoreItaly: Approves budget Law for 2018
The Italian Budget Law for 2018 (Law no. 205 of 27 December 2017) published on 29 December 2017 and entered into force on 1 January 2018. Some of its most significant corporate tax measures are summarized below: Dividends: Dividends from
See MoreSpain: Council of Ministers approves the amendment of several tax regulations
On 29 December 2019, the Council of Ministers approved a Royal Decree-Law to extend and approve various tax measures and other urgent measures on social issues, which provides for the coefficients to update cadastral values for 2018. The Decree
See MoreArgentina: Government reforms transfer pricing rules via Decree 1112/2017
The government has issued a Decree No.1112/2017 on December 29, 2017, for enacting and making effective of comprehensive tax reform. It also contains the new rules for transfer pricing. According to the new Law, transactions with parties in low-tax
See MoreTransfer Pricing Brief: December 2017
Italy: CbC Reporting requirement-Timing: On December 11, the tax authority issued a Measure no. 288555 extending the due date for filing the CbC report for fiscal year 2016 from 31 December 2017 to 9 February 2018 within 60 days following the
See MoreUkraine changes in Transfer Pricing Rules from January 1, 2018
On 7 December 2017, the Ukrainian Parliament passed the Law of Ukraine "On Amendments to the Tax Code of Ukraine and Certain Laws of Ukraine on Securing Balance of Budget Revenues in 2018” No. 2245-VIII (“Law”). The law came into force on 1
See MoreItaly: Approval of 2018 Budget Bill including new tax on digital services
The main agenda of this Bill being approved by the Italian Senate was to offset differences on tax on digital services so that it can target large multinational companies like Facebook, Apple and Google providing digital services in Italy. Italy has
See MoreHungary: Deadlines of Country-by-Country reporting and notification requirements
Issues have been generating recently on filling Hungary’s CbC reporting notification on the 17T201T form. A Hungarian resident entity is not required to file the CbC notification requirement until or unless the multi-national group has a
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