Korea- proposed changes to the country-by-country reporting requirements
The Ministry of Strategy and Finance of South Korea published a proposal for detailed procedures of the country -by country reporting requirements on 28 December 2016. The proposal requires the provision of a full report on cross-border transactions
See MorePoland: Amendments regarding TP documentation come into effect
Corporate Income Tax Law amendments gazetted in the Official Journal 1932/2015 regarding transfer pricing (TP) reporting obligations in line with Action 13 of the OECD Base Erosion and Profit Shifting (BEPS) project came into effect on 1 January
See MoreSouth Africa: SARS issues final regulations on country-by-country (CbC) reporting
The South African Revenue Service has issued final regulations on country-by-country (CbC) reporting on 23 December 2016. The regulations specify the changes to the Country-by-Country Reporting Standard for Multinational Enterprises (“MNEs”)
See MorePakistan: FBR Publishes Audit policy 2016
The new Audit Policy 2016, approved by the Federal Board of Revenue (FBR) on 3 January 2017 for selection of taxpayers for audit, would also include those cases in the parametric selection process which were earlier selected for audit last year.
See MoreIceland: Ministry of Finance publishes regulation on country-by-country reporting
The Ministry of Finance and the Economy published Regulation No. 1166/2016 on the submission of country-by-country reports (CbC) on 22 December 2016. Under the article 3 of the regulation, Iceland’s parent company resident need to submit a CbC
See MoreBelgium: CbC reporting deadline extended
The Federal Public Service of Belgium declared an extension of the deadline until 30 September 2017 to inform the tax administration that the parent corporation will file a consolidated country by country (CbC) report for the year 2016 in another
See MoreChile: CbC reporting implemented
The Tax Authority of Chile published Resolution 126 on 27th December 2016 to implement country-by-country (CbC) reporting. It requires specific taxpayers to submit an annual report to the tax authority disclosing the level of income, profit or
See MoreChina published a report of APAs 2015
On 23 December 2016, Chinese State Administration of Taxation published the Advance Pricing Agreement (APA) Report of 2015. This report of 2015 contains statistics of APAs that China concluded from 2005 to 2015. China has concluded 6 bilateral and 6
See MoreCzech Republic: Bill introducing CbC reporting submitted to parliament
The government of Czech Republic has submitted a bill on 22nd December 2016 to the parliament, which, if approved, would announce changes to the Law on International Cooperation in the Administration of Taxes. It would implement the provisions
See MoreLuxembourg: Parliament adopts country-by-country reporting
The Luxembourg Parliament on 13 December 2016 passed legislation implementing country- by-country (CbC) reporting requirements for Luxembourg entities that are part of a Multinational Enterprise Group (MNE Group). The new CbC reporting legislation
See MoreHong Kong: IRD released country-by-country reporting
The Inland Revenue Department on 22 December 2016 published on its website an announcement on country-by-country (CbC) reporting. The CbC report requires aggregate tax jurisdiction-wide information relating to the global allocation of the income,
See MoreSingapore- Voluntary filing of CbC Reports for Singaporean tax resident MNE groups for fiscal year 2016
The Inland Revenue Authority of Singapore (IRAS) announced on 19 December 2016 that the voluntary filings for Singaporean multinational enterprise groups for financial year 2016 will be allowed and this follows the e-tax guide of the
See MoreSpain: Tax authority announced model country-by-country reporting form
Recently the Spanish tax authorities published a communication announcing the submission of a model country-by-country (CbC) reporting form (231). The form has not yet been approved. Under the Spanish corporate income tax regulations any entity or
See MoreKorea-Tax reform bill of 2017 enacted
Korea enacted the tax reform bill of 2017 on 20 December 2016 which was approved by the National Assembly on 2 December 2016. According to the Tax Reform of 2017 domestic merged brother-sister companies would be considered as tax free if and only
See MoreUkraine-Adopted amendments to Tax Code
The parliament of Ukraine adopted a draft law amending the Tax Code on 21 December 2016. According to the adopted law, costs for repairing and maintenance of non-productive fixed assets will no longer be considered as deductible expenses. Previously
See MoreUruguay- New transfer pricing requirements for corporations with income derived from tax-exempt activities
The Tax Authority of Uruguay issued Ruling No. 5,947 on 6 December 2016 according to which a corporation conducts business with foreign related companies with income derived from a tax-exempt activity will be subject to the transfer pricing
See MoreMalta: Guidance on the use of MAP published
On 15 Dec 2016, The Commissioner for Revenue has published guidance issued under the provisions of article 96(2) of the Income Tax Act (ITA) on the use of Mutual Assistance Procedure
See MorePortugal- Extension of the deadline for filing Country-by-Country reporting notification
The Secretary of State for Tax Affairs’ Office of Portugal published Decree no.254/2016-XXI (dated 12 December 2016) on 15 December 2016 which extends the deadline to submit the mandatory Country-by-Country (CbCR) notification for the fiscal year
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