US: IRS issued CBC draft form
The US Internal Revenue Service (IRS) has issued a draft of IRS Form 8975 (Country-by-Country Report) that will be used for country-by-country (CbC) reporting by the US persons that are the ultimate parent entity of a multinational enterprise (MNE)
See MoreBelgium issues TP documentation forms and instructions
During June 2016, Belgium has introduced mandatory transfer pricing documentation and country-by-country (CbC) reporting requirements in accordance with Base Erosion and Profit Shifting (BEPS) Action 13 of the Organisation for Economic Co-operation
See MoreJersey: Country-by-country reporting announced
The Taxation Regulation 2016 of Jersey regarding Country-by-country reporting has been made on 14th December 2016 and the regulations will entry into force on 21st December 2016. It covers a country-by-country (CbC) reporting obligation for
See MoreColombia: DIAN rules to keep accounting records
According to ruling 31252 of 2016, the tax authority of Colombia (DIAN) pronounced on the obligation for taxpayers to keep accounting records. Commerce Code article 19 provides that individuals and companies considered to be merchants are obliged to
See MoreIreland: CbC reporting notification deadline
On 1 January 2016, Ireland’s new Country-by-Country (CbC) reporting requirements took effect. The Irish CbC requirements require certain Irish parented groups, and in specific instances, domestic subsidiaries of foreign parented groups, to report
See MoreCyprus: Tax authority published circular on transfer pricing adjustment
The Cyprus Tax Department on 24 November 2016 issued Circular 2016/15 clarifying the application of article 33 of the Income Tax Law. Article 33 allows the tax authorities to adjust transactions between related parties on terms which, in the opinion
See MoreFrance-CbC reporting requirements conflicting to constitution
The Constitutional Court provided its decision on 8 December 2016 regarding the compatibility with the constitution of the public country-by-country (CbC) reporting requirements introduced through the bill on transparency, the fight against
See MoreCosta Rica: A discussion draft published for comments on Transfer pricing documentation guidelines
The Costa Rican Ministry of Finance published a discussion draft on 12 December 2016 on a resolution regarding guidelines on transfer pricing documentation. The requirements under the guideline set out the operations of companies within the economic
See MoreDenmark: Issues CbC notification rules
The Danish tax authorities (SKAT) on 9 December 2016 announced that country-by-country (CbC) notifications must be submitted electronically and in a standardised format on Form 05.034. The form contains instructions both in English and Danish, and
See MoreNorway: Country-by-country reporting under BEPS Action 13
Finance Minister of Norway published a regulation on country-by-country reporting legislation based on proposal under Action 13 of the BEPS Action Plan on 9 December 2016. . Norway’s CbC reporting regulation will be effective from beginning of the
See MoreTransfer Pricing Brief: November 2016
Malaysia: Penalty for non-compliance of CbC reporting: The fiscal Budget for 2016 has proposed a penalty between MYR 20,000–100,000 or imprisonment of not more than 6 months, or both, for an incorrect return or failure to comply with CbC
See MoreBrazil: Publishes proposed Country-by-Country reporting rules
The Brazilian Federal Revenue Agency on 4 November 2016, published a proposed Normative Instruction to establish country-by-country reporting (CbCR) rules in Brazil for Multinational groups where the ultimate parent company is a resident in Brazil
See MorePoland: Publishes new reporting requirements for taxpayers
A customized draft act on the exchange of tax information with other states dated October 7, 2016 has been released on the websites of the Polish Government Legislation Center. The Polish legislature has decided to move the regulations on CbC
See MoreBolivia: Publishes audit procedure rules
The National Tax Service published Resolution No. 10-0032-16 (the Resolution) on 27 November 2016. The Resolution contains the formalities to be observed by the tax authorities during an audit procedure carried out to verify tax liabilities
See MoreIndia: Signs A further five unilateral advance pricing agreements
India's Central Board of Direct Taxes has entered into a further five unilateral advance pricing agreements (APAs). The APAs were signed on 27 October 2016 with Indian taxpayers operating in various sectors, including manufacturing and
See MoreSweden: Submits proposals for the implementation of CbC reporting bill
Proposals for the implementation of country-by-country transfer pricing reporting have been submitted to Sweden's Council on Legislation alongside a draft law to transpose the updated EU Directive on administrative cooperation. According to an
See MoreColombia: Tax reform bill 2016
The comprehensive tax reform bill 2016 recently submitted by the government of Colombia to the Congress with the following corporate income tax issues: Rates: The bill proposes to unify the income tax and the Fairness Tax into a single income tax
See MoreGreece: Draft Bill to amend Income Tax Code submitted to parliament
The amendments of the draft law implementing Directive 2014/17/EU on credit agreements for consumers regarding residential immovable property and amending Directives 2008/48/EC has been submitted to the parliament on 23rd November 2016. The
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