Dominican Republic: DGII publishes the sixth version of the transfer pricing information
Recently, the Dominican Republic Tax Authorities (DGII) published the 6th version of the transfer pricing information return (DIOR) through its virtual platform. The content of the form has been simplified to guarantee the accuracy and organization
See MoreSwitzerland: Ordinance on exchange of CbC reports adopted
On 29 September 2017, Swiss Federal Council adopted an ordinance on the international automatic exchange of country-by-country reports on multinational firms. The exchange of country-by-country reports between Switzerland and its partner states
See MoreJapan publishes guidance for taxpayers on the MAPs
Recently, the National Tax Agency of Japan has released a guidance on mutual agreement procedures (MAP) on their website. This guidance has been prepared based on the recommendation 2.1 indicated in the final report on Action 14 (Making Dispute
See MoreUruguay: Regulations on common reporting standard (CRS) issued
On 25 September 2017, the Tax Authority issued Resolution No. 6.396/017 providing instructions to financial institutions for reporting information under the Common Reporting Standard (CRS) guided by OECD. Under the CRS, Financial institutions are
See MoreArgentina: General Resolution 4130-E publishes in Official Gazette
The Federal Tax Administration (FTA), on September 20, 2017, published the General Resolution 4130-E in the Official Gazette. It establishes the country-by-country (CbC) guiding framework in Argentina and is applicable to ultimate parent entities of
See MoreGuernsey: The Beneficial Ownership of Legal Persons Law enacted
The Beneficial Ownership of Legal Persons (Guernsey) Law, 2017 came into force on 15 August 2017. The Law establishes the Office of the Registrar of Beneficial Ownership of Legal Persons, sets out the powers and functions of the Registrar, and
See MoreNicaragua: Transfer pricing legislations are in effect as of 30 June 2017
The transfer pricing rules are in effect as of 30 June 2017 which was enacted by the Nicaraguan Congress through Law No. 822 of 2012. Law No. 822, enacted on 12 December 2012, contains the Nicaraguan transfer pricing rules that were intended to
See MoreMalaysia: IRBM publishes sample notification letters for CbC reporting
The Inland Revenue Board of Malaysia (IBRM) has recently published two different sample notification letters for entities subject to the country-by-country (CbC) reporting notification requirement. Two separate sample notifications letters have been
See MoreLuxembourg: Tax authority publishes circular on mutual agreement procedure
To set out the procedures for the implementation of the mutual agreement procedure (MAP), on 28 August 2017, the Director of Taxes published Circular L.G. Conv. D.I. No. 60. The MAP intends to eliminate legal and economic double taxation. The MAP
See MoreSpain: Tax authority publishes new form for reporting related-party transactions
On 30 August 2017, a new Form 232 is published through a Gazette Order that updates certain existing reporting obligations in connection to related-party transactions and transactions involving parties located in countries or territories identified
See MoreNetherlands: Tax plan for 2018
The Dutch government has presented the tax plan for 2018 on 19th September 2017. If adopted, these proposals will be entered into force on 1st January 2018. 2018 tax plan contains various other amendments on a variety of topic and these are given
See MoreLithuania: Approves country-by-country reporting rules
On 31 May 2017, the Lithuanian Tax Administrator has approved (Order No VA–47) the reporting rules for the multinational enterprise also known as country by country (CbC) reporting rules. These rules came into force as of 5 June 2017. Under this
See MoreColombia issues draft decree on transfer pricing regulations
The Ministry of Finance and Public Credit of Colombia issued a draft decree 1625 of 2016 concerning transfer pricing documentation for public consultation on 11 August 2017. The major issues in the proposed decree are business restructuring rules,
See MoreHungary: Draft law published on amended transfer pricing documentation requirements
The Hungarian government has finalized the draft legislation concerning amended transfer pricing documentation requirements which will be presented to the parliament in the autumn of 2017. Hungary is expected to introduce rules regarding Master file
See MoreUK: Second Finance Bill of 2017 published
On 8 September 2017 the UK government published the second Finance Bill of 2017. This second Finance Bill was necessary because not all the legislative changes announced in the autumn statement 2016 and budget proposals for 2017 could be included in
See MoreAustralia: Consultation on Consolidation Integrity Measures
On 11 September 2017, the Minister for Revenue and Financial Services released draft tax consolidation legislation and an explanatory memorandum for public consultation. These important measures restore integrity to the tax consolidation rules. The
See MoreU.S. and UK sign an agreement on the exchange of CbC reports
According to an announcement on the IRS website, the competent authorities of the U.S. and United Kingdom have concluded an arrangement for the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of
See MoreMorocco: New procedures for APAs
Morocco published a Decree No. 2.16.571 of 3 July 2017 in the Official Gazette No. 6594 on August 10, 2017 that describes the procedure for concluding advance pricing agreements (APAs). This decree was published in Arabic language. For example, a
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