Transfer Pricing Brief: August 2017
Brazil: CbC reporting requirement: According to NI 1,722/2017 published in the Official Gazette on 17 July 2017, transitional provisions apply if a legal entity which is resident in Brazil for tax purposes and which is not the ultimate
See MoreOECD: Global Forum releases compliance ratings on tax transparency
On 21 August 2017 the Global Forum on Transparency and Exchange of Information for Tax Purposes published the first ten results of the enhanced peer review process to assess compliance with international standards for the exchange of information on
See MoreColombia changes rules of amortization of intangible assets
Colombian National Tax Authority (DIAN) has published a ruling regarding the application of amortization of intangible assets. In accordance with ruling, amortization method of an intangible must be decided based on the accounting rules, as long as
See MoreBelgian tax authority declared CbC reporting notification deadline
According to Belgian law enterprises that meet the country-by-country (CbC) thresholds requirement will have to provide the first CbC reporting notifications to the tax authorities by 30 September 2017. For this first year’s notification, an
See MoreSlovenia publishes detailed guidelines on CbC reporting
The Ministry of Finance (MoF) on 26 July 2017, issued detailed guidelines for Country-by-Country (CbC) reporting. The guidelines also include the form and instructions for submitting the CbC reporting notification and require the following essential
See MoreUK: HMRC confirms CbC reporting format for multinationals
On 15 August 2017, HM Revenue & Customs (HMRC) released guidance confirming the format and method of filing country-by-country (CbC) reports that are due in the UK. The UK follows the CbC reporting requirements of the Organisation for Economic
See MoreBulgaria: CbC reporting legislation adopted through significant changes to TSSPC
A Law on Amendment and Supplementation of the Tax and Social Security Procedure Code (TSSPC) was published in issue 63/04.08.2017 of the State Gazette. The country-by-country reporting (“CbCR”) legislation introduced by the Directive is
See MoreBelgium adopts draft bill to implement EU directives on automatic exchange of information
The Belgian parliament adopted the draft bill to implement the EU Directive 2014/107/EU for mandatory automatic exchange of information, on 20 July 2017 and the bill was published in the Belgian Official Gazette, on 11 August 2017. The Bill
See MoreKorea: 2017 tax reform proposals announced
The government of South Korea is planning to increase the tax rate for large companies and high-earning individuals with the hope of reducing inequality. With this aim, Korea’s Ministry of Strategy and Finance announced the 2017 tax reform
See MoreLatvia: State Revenue Service announces CbC reporting regulations
The Latvian State Revenue Service (SRS) on 08 August 2017 announced the Country-by-Country (CbC) reporting regulations, which were approved by the Latvian Cabinet in July following an amendment to the Law on Taxes and Duties to require CbC reports.
See MorePakistan implements documentation and CbC reporting requirements
In Pakistan until 2016, no transfer pricing documentation was required under the Income Tax Ordinance (ITO). However, with effect from 1 July 2016, the Government has approved the new legislation to effectively implement the Country-by-Country
See MoreIndia: Multilateral Competent Authority Agreement on Exchange of CbC reports enters into force
The Ministry of Finance on 28 July 2017 has issued a Notification (No. 75/2017), which announces that the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country (CbC) Reports entered into force for India on 12 May 2016 and
See MoreUS: IRS now accepting CbC reports
On 11 August 2017 the US IRS in its latest bulletin of news and information on country by country (CbC) reporting advised that parent entities of U.S. multinational enterprise (MNE) groups with $850 million or more of revenues in a previous annual
See MoreU.S. and Estonia sign an agreement on the exchange of CbC reports
According to an IRS announcement on its website, the competent authorities of the U.S. and Estonia have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of
See MoreGreece: Law 4484/2017 regarding TP documentation requirements publishes
The Law 4484/2017 entitled "Adaptation of Greek Legislation to the provisions of Directive (EU) 2016/881 and other provisions" was published in the Government Gazette on August 1, 2017. It harmonizes Greek legislation with the provisions of Council
See MoreBrazil publishes amended regulation on CbC reporting
Normative Instruction 1,722/2017 published in Brazil’s Official Gazette on 17th July 2017 amends Normative Instruction 1,681/2016 relating to guidance on CbC reporting. According to NI 1,722/2017, transitional provisions apply if a legal entity
See MoreIndia: Tribunal decision on foreign exchange fluctuation gain or loss and arm’s length pricing
The Income-tax Appellate Tribunal in the case of ACIT v. Rajratna Metal Industries Ltd. held that a foreign exchange fluctuation gain/loss is an operating item and is not to be excluded for the purpose of computing the arm’s length price
See MoreMalawi: Tax authority publishes transfer pricing regulations 2017
On 3 July 2017 the Malawi revenue authority published Gazette Notice No 36 of 2017 regarding Taxation (Transfer Pricing Documentation) Regulations 2017. According to the regulation, taxpayers are required to conform to contemporaneous documentation
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