Slovenia publishes CbC reporting guidelines
The Slovenian Financial Administration published a new guidance on the implementation of country-by-country (CbC) reporting on 12 January 2017. The new guidelines included in Action 13 of the OECD Action Plan on Base Erosion and Profit Shifting and
See MoreUS: IRS release guidance on country-by-country report filing process
The US Internal Revenue Service (IRS) issued Revenue Procedure 2017-23 on 19 January 2017 describing the process for filing Form 8975, Country-byCountry Report, and accompanying Schedules A, Tax Jurisdiction and Constituent Entity Information
See MoreBrazil issues tax regulation program
Provisional Measure 766 has issued and released on 4 January 2017. This provisional measure establishes a tax regulation program for Brazilian taxpayers to settle their tax liabilities. Under this program, taxpayers can resolve their federal tax
See MoreIsle of Man: New regulations for accounting records
On 20 January 2017, the income tax regulations 2016 come into effect for accounts and financial records and in accordance with this regulation taxpayers are required to store accounts and financial records for at least 5 years. Non-compliance with
See MoreIndia: Loss making company couldn’t be excluded from comparable list if it satisfies comparability analysis
The Ahmedabad Bench of Income-tax Appellate Tribunal in case of: Erhardt+Leimer (India) Private Limited v. ACIT (ITA Nos. 3298/Ahd/2011 & 2880/Ahd/2012) held that consistent loss-making companies cannot be rejected as comparable unless the
See MorePuerto Rico proposes transfer pricing rules
The Department of Treasury has released proposed regulations on 19 November 2016 regarding section 1040.09 of the Puerto Rico Internal Revenue Code of 2011. The proposal highlights US transfer pricing rules and guidelines from the Organization for
See MoreSingapore: Detailed guidance on MAP for DTAs
The Inland Revenue Authority of Singapore introduced new guidance on the mutual agreement procedure (MAP) on 12 January 2017. The guidance has provided detail procedures for the MAP. According to new guidance, the MAP will be available to those
See MoreMalta: IRD issues Guidelines on use of Mutual Agreement Procedure
The Inland Revenue Department of Malta issued guidelines for the use of the Mutual Agreement Procedure under the provisions of Article 96(2) of the Income Tax Act (ITA), on 15 December 2016. The procedure permits the Malta Competent Authority to
See MoreChile: Announcement on entry into force of new tax regime
The Tax Administration of Chile announced on 5th January 2017 that a new tax regime enters into force from 1st January 2017 as introduced by the 2014 Tax Reform. Companies under the attributed income regime have to pay first category tax at a
See MoreSpain: Government approves CbC reporting form
The country-by-country (CbC) reporting form 231 approved on 30 December 2016 in an order no. HFP/1978/2016 of 28 December 2016. The CbC report must be submitted by a company resident in Spain that is the parent company of a corporate group for the
See MoreBrazil: Regulation on CbC reporting
Normative Instruction 1,681/2016 was issued in the Official Gazette on 29 December 2016 regarding annual country-by-country (CbC) reporting. According to Normative Instruction 1,681/2016: Legal entities resident in Brazil are obliged to
See MorePeru :Amendments to Transfer Pricing rules
In Peru, Law Decree No. 1312 was published on 31 December 2016. The Decree amended the existing Transfer pricing reporting requirement by accepting the proposed changes by the Organization for Economic Cooperation and Development (OECD) within the
See MoreAzerbaijan-Published amendments to the Tax Code related to Transfer Pricing rules
The new amendments to the Azerbaijani Tax Code were published on 25 December 2016. The amendments introduced new Transfer Pricing provisions to the Tax Code. These amendments are effective from 1 January 2017. According to the new rules taxes may
See MoreTurkey: Bilateral APA signed
The Revenue Administration stated on 30th December 2016 that it had signed a new bilateral advance pricing agreement and this agreement is based on article 13 of Corporate Income Tax Law No.
See MoreTransfer Pricing Brief: December 2016
Norway: BEPS related compliance General rule for Country by Country (CbC) reporting: Norway has introduced Country-by-Country (CbC) reporting requirement for domestic entities with an annual consolidated group revenue of NOK 6.5 billion
See MoreLuxembourg: Tax authorities issued transfer pricing circular
The Luxembourg tax authorities issued a new circular addressing the tax treatment of companies engaged in intra-group financing transactions. On 27 December 2016, Circular L.I.R. n°56/1 – 56bis/1 is released which replaces and supersedes the
See MoreMexico issued transfer pricing adjustment rule
Mexican tax authorities has been issued rule 3.9.1 of the Miscellaneous Rule on 8 December 2016 regarding transfer pricing adjustments.The rule establishes that all transfer pricing adjustments should be reflected in the tax return in which the
See MoreCanada: Final legislation on implementation of CbC reporting requirements
Bill C-29 was passed by the House of Commons on 15th December 2016. The Bill provides the final legislation to implement country-by-country (CbC) reporting. The final legislation formalizes the introduction of section 233.8 to the Income Tax Act,
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