Transfer Pricing Brief: November 2017
Belgium: Main corporate income tax rate: On 27 October 2017, the government has approved the corporate tax reform bill. The rate of corporate income tax will be gradually reduced to 29% in 2018, and will be further reduce to 25% in 2020. Belgium
See MoreUK: Autumn Budget Announcements 2017
The UK’s autumn budget measures were announced on 22 November 2017. Important measures affecting business are as follows: R & D Tax Relief The Research & Development Expenditure Credit (RDEC) rate available to companies claiming under
See MoreMexico releases online platform for Transfer Pricing Informative Returns
On 1 November 2017, the Mexican Tax Administration (SAT) released the online platform and digital formats for the new informative statements for taxpayers required to submit the new Transfer Pricing Informative Returns under Article 76-A of the
See MoreIrish Revenue reschedules CbC reporting deadline
On 24 November 2017, the Irish Revenue published an eBrief No. 107/17 update stating that “Due to the late availability of the Country-by-Country (CbC) Reporting filing facility, it will remain open for, and accept, CbC Reports for fiscal years
See MoreNorway publishes updated guidelines on CbC reporting
The Tax and Customs Administration issued updated guidelines for the submission of the country-by-country reporting form RF-1352 (CbC) on 17th November 2017. According to the guidelines, CbC reports must be submitted by 31st December
See MoreAustralia releases draft legislation to address hybrid mismatch
24 November 2017, Australia’s Treasurer released exposure draft legislation to address hybrid mismatch arrangements reaffirms the Turnbull Government’s continued focus on strengthening the integrity of Australia’s tax system, and stamping out
See MorePakistan: FBR publishes rules for documentation and CbC reporting requirements
On 16 November 2017, the Federal Board of Revenue (FBR) in Pakistan has published SRO 1191(1)/2017, which includes chapter VIA to the Income Tax Rules of 2002. The new Chapter (VIA) identifies the reporting entities, clarifies the reporting
See MoreRussia approved draft law on automatic international exchange of tax information and documentation requirements
The Russian State Duma adopted in the final reading the draft law implementing international automatic exchange of financial accounting information and transfer pricing (TP) documentation of multinational Groups of Companies on 16 November 2017.
See MorePeru: Amendments made to local file reporting requirement
The Peruvian Government issued transfer pricing (TP) regulations (Supreme Decree N° 333-2007-EF) on 17 November 2017 with detail guidance on the preparation and submission of the country-by country (CbC) report. According to amendments made to
See MoreFrance: Government publishes draft second Amendment Financing Act for 2017
On 15 November 2017, a second draft amending Finance Bill for 2017 was submitted to the French Council of Ministers and was submitted to the French Parliament. The draft law emphasized the following tax measures for the coming year. Anti-Evasion
See MoreCosta Rica: Tax administration publishes draft resolution on CbC reporting
On 26 October 2017, Costa Rica’s tax administration released a draft version of a resolution that would require multinational enterprises (MNEs) to file a country-by-country (CbC) report. According to draft resolution, all Costa Rican tax resident
See MoreUK enacts interest restriction rules
On 16 November 2017, the new corporate interest restriction rules were enacted in Finance (No.2) Act 2017 that received Royal Assent to impose an additional potential restriction on UK tax relief for finance costs, after the existing tax rules
See MoreTaiwan: MoF announces changes to the transfer pricing documentation rules
The Ministry of Finance (MoF) published the amendment of Transfer Pricing Audit Rules on 13th November 2017. The rules established three-tiered transfer pricing documentation in accordance with the OECD under the base erosion and profit shifting
See MoreRomania: Guidance published on form for country-by-country reporting
On 14 November 2017, the tax administration published guidance Order no. 3049/2017 concerning the form to be used for filing country-by-country (CbC) reports. According to Order no. 3049/2017, the “country-by-country reporting” form should be
See MoreSweden: Income of pension funds to be included in the CbC reporting
The Swedish Tax Agency on 8 November 2017, has published a clarification (No. 202 439672-17/111) on any pension funds derived by life insurance companies, foreign occupational retirement institutions and pension funds pay are to be regarded as
See MoreUS: IRS releases practice units on APAs for tangible goods transactions
On November 6, 2017, the Internal Revenue Service (IRS) released two new international Practice Units (IPUs) in connection with Advance Pricing Agreements (APAs) for inbound and outbound tangible goods transactions. The IPUs provide a summary of the
See MoreUkraine clarifies classification of transactions with a non-resident legal entity
On October 4, 2017, the State Fiscal Service (SFS) published Letter No. 1945/6 / 99-99-15-02-02-15 / IPK of September 13, 2017, which specifies the classification of transactions with a non-resident legal entity for the purpose of transfer
See MoreQatar joins BEPS inclusive framework and signs BEPS Multilateral Instrument
The Organization for Economic Co-operation and Development (OECD) made an announcement on November 14, 2017, that Qatar joined the Base Erosion and Profit Shifting (BEPS) inclusive Framework. The BEPS inclusive framework is a group of countries that
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