Serbia 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
See MoreUS: IRS increases the fees for advance pricing agreements
On 6 February 2018, the Internal Revenue Service (IRS) announced that fees for Advance Pricing Agreements (APAs) are expected to increase in a two-step process. For APA requests submitted after June 30, 2018, the fees will increase as follows:
See MoreTurkey: General Communiqué No. 3 regarding APAs publishes in the official gazette
The General Communiqué No. 3 regarding application process of Advance Pricing Agreements (APAs) was published on December 7, 2017 in the official gazette. It was entered into force on the similar day of its publication in the official gazette. The
See MoreRussia: MoF clarification on application of thin capitalization rules in the context of tax treaties
Recently, the Ministry of Finance (MoF) issued a Guidance Letter (No. 03-03-06/1/87340) and clarified the application of domestic thin capitalization rules in the context of tax treaties. According to a statement by the MoF, interest paid by a
See MoreCanada: MLI ratification process begins
The Parliamentary Secretary on behalf of the Minister of Foreign Affairs, Matt DeCourcey, had presented the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on January 31, 2018,
See MoreCzech Republic: Proposed amendments to income tax for 2019
Recently, Finance Ministry has published the first draft copy of the amendment to the Income Tax Act for comments. These amendments are supposed to be started from year 2019. The proposed personal income tax rate of 19% is 1.1% less than the present
See MoreCzech Republic: Cabinet approves ratification of BEPS MLI
The Cabinet of Czech Republic on February 14, 2018, approved ratification of the Multilateral Instrument (MLI) to implement into bilateral tax treaties the tax treaty-related measures arising from the OECD / G20 BEPS Project to tackle base erosion
See MoreJamaica and five more countries sign MLI to implement tax treaty related BEPS measures
On 24 January 2018, the Ministers and high-level officials from Jamaica, Malaysia, Panama, Barbados, Côte d’Ivoire and Tunisia have signed the BEPS Multilateral instrument (MLI) to amend double tax treaties to bring into effect changes designed
See MoreNorway: Government publishes new guidance on MAP
The Norwegian Government published detailed taxpayer guidance on the mutual agreement procedure (MAP) framework set out in Norway’s tax treaties on 7th February 2018. It is an instrument which shall ensure that states apply the tax treaties
See MoreUkraine: SFS publishes guidance letter on definition of related parties
On 5 February 2018, the State Fiscal Service (SFS) published Guidance Letter No. 204/6/99-99-15-02-02-15/IPK of 18 January 2018 clarifying definition of related parties regarding holding ownership of a director who owns the corporate
See MoreIreland updates rates of Corporation Tax
On 12 February 2018, the Revenue department of Ireland has published an eBrief No. 019/18, amendment to Revenue Tax and Duty Manual Part 02-02-02 - The charge to and rates of Corporation Tax - has been amended as follows: To provide guidance
See MoreHong Kong: IRD gazettes law on joining multilateral tax agreement
On 2 February 2018, the Inland Revenue Department published a law in the official gazette outlining the legal framework for Hong Kong to join a multilateral tax agreement on implementing automatic exchange of information in tax matters (AEOI),
See MoreUkraine clarifies the definition of controlled transactions for transfer pricing purposes
On 19 January 2018, the State Fiscal Service (SFS) released Guidance Letter No. 119/6 / 99-99-15-02-02-15 / IPK of January 12, 2018, which defines the definition of controlled transactions for cross border transaction purposes. Under the amendments
See MoreIndia: Budget 2018 proposes rules for implementation CbC reporting requirements
On 1 February 2018, the Finance Minister presented the Union Budget 2018. The budget includes proposals to clarify rules for implementation of the country-by-country (CbC) reporting requirements. Consequently, the due date for submits the CbC
See MoreFinland: Tax administration publishes new guidance on TP documentation
On 29 January 2018, the tax administration issued the new guidance No.A129/200/2017 on transfer pricing documentation, which replaces the previous guidance of 2007. The documentation requirement is divided into a master file and a local file. The
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