Costa Rica: Tax administration Gazettes CbC reporting resolution
On 2 February 2018, Costa Rica published the Resolution no.DGT-R-001-2018. Resolution No.DGT-R-001-2018 requires multinationals to submit a CbC report in accordance with the OECD's recommendations for the erosion and profit shifting base (BEPS)
See MoreMalaysia: IRBM amends the APA rules and updates the MAP guidelines
Recently, the MIRB (Malaysia Inland Revenue Board) has published an amendment to the APA Rules and the updated Mutual Agreement Procedure (“MAP”) Guidelines. The APA rules referred to as the Income Tax (Advance Pricing Arrangement) Rules 2012
See MoreAustralia: Guidelines on attribution of ADI equity capital and controlled foreign entity equity
On 24 January 2018, the Australian Taxation Office (ATO) issued the Practical Compliance Guideline (PCG) 2018/1. This Guideline sets out how the ATO will administer subsection 820-300(3) of the Income Tax Assessment Act 1997 (ITAA
See MorePakistan: FBR publishes amendments to CbC reporting requirements
On 31 January 2018, the Federal Board of Revenue (FBR) in Pakistan has published SRO no. 99(I)/2018, which provides amendments to draft rules that establish transfer pricing documentation and country-by-country (CbC) reporting requirements for large
See MoreLithuania proposes new transfer pricing rules
On 15 January 2018, a draft order amending the regulations of controlled transactions was issued by the Ministry of Finance of the Republic of Lithuania (to amend the Order No. 1K-123 dated 9 April 2004). The main points in the draft order are the
See MoreTransfer Pricing Brief: January 2018
Hong Kong: CbC reporting requirement-General rule: Inland Revenue (Amendment) (No. 6) Bill 2017 published on 29 December 2017 sets out rules on transfer pricing documentation including country-by-country reporting, and contains other measures to
See MoreFrance: Requirement for Transfer Pricing Documentations being brought in
After disappearing from the draft, the Finance Bill 2018 undergoes revision of the last year’s requirements for transfer pricing documentation and brings in some additional changes to the requirements: Failure within the ambit of the
See MoreUS: President signs Tax Cuts and Jobs Act
Congress has passed the Tax Cuts and Jobs Act(the Act), and the President signed it on December 22, 2017. The most important changes in the area of corporate taxation are: Main corporate tax rate: Under the new Act, the corporate tax rate
See MoreIndia: Finance Minister presents Budget for the year 2018-19
Indian Finance Minister Arun Jaitley today disclosed its budget 2018-2019 for the fiscal year starting from 1 April 2018. The budget is largely focused on uplift of agricultural sector, along with major push to healthcare and education sectors in
See MoreFinland:Ministry of Finance publishes draft bill on deduction of interest payment
On January 19, 2018, the Finnish Ministry of Finance published a draft government bill containing proposed changes on the deduction of interest paid to related parties. The Ministry of Finance has requested comments from interested parties by the
See MorePeru: Tax authority issues ruling on deadline for submitting local file
On 18 January 2018, the Peruvian tax authorities (SUNAT) issued Ruling N° 014-2018/SUNAT requiring taxpayers to electronically submit the local file on an annual basis in June of the following year. The due date for the submission of the first
See MoreMozambique: 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
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