Colombia publishes newly proposed TP regulations
Tax Authorities of Colombia (DIAN) published a proposed transfer pricing (TP) regulations to execute the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Action 13 and to establish the
See MoreCzech Republic: CbC reporting requirements implementation
The Law No. 305/2017 was published on September 20, 2017 in the official gazette for implementing EU Directive 2016/881 on the exchange of country-by-country (CbC) reporting information among EU member states. The closing date is October 31, 2017
See MoreIndia: CBDT releases CbC reporting and Master file documentation rules for public comment
The Central Board of Direct Taxes (CBDT) published a draft guideline for framing Rules in respect of Country-by-Country reporting and furnishing of master file on 6 October 2017. The comments and suggestions on the draft rules can be submitted by 16
See MoreCyprus: Tax department announces the commencement of CbC reporting notification
On 09 October 2017, the Cyprus Tax Department informed that the submission of notification for country by country reporting for the year 2016 has started. The process will be performed through the Government Gateway Portal ‘Ariadni’. The
See MoreKazakhstan: New Tax Code submits to Parliament
The First Vice-Minister of National Economy, Ruslan Dalenov, submitted the draft of the new tax code to the finance and budget committee of the lower house of the Kazakh parliament (the Mazhilis) on September 21, 2017 for consideration. It was
See MoreUS: IRS appeals its tax court loss in the amazon transfer pricing case
On 29 September 2017, the Internal Revenue Service filed an appeal against March Tax Court ruling concerning Amazon’s cost-sharing agreement buy-in payment. The case is important because it is expected to provide fundamental guidance on the
See MoreU.S. signs agreements on the exchange of CbC reports with five countries
According to an IRS announcement on its website, it has signed separate agreements with the Czech Republic, Finland, Greece, Italy, and Sweden to exchange country-by-country reports on multinationals. Country-by-Country reporting data will be
See MoreJersey: Draft Budget 2018 Published
The Government published the Draft Budget 2018 on October 3, 2017. This budget constructs the package of measures agreed in the Medium Term Financial Plan (MTFP), combining savings, efficiencies and revenue raising measures to enable investment in
See MoreTransfer Pricing Brief: September 2017
Taiwan: Main corporate income tax rate: On 1 September 2017, Taiwan’s Ministry of Finance released tax reform proposals including to increase the corporate income tax (CIT) rate from 17% to 20%. The Proposal will become effective for taxable
See MoreAngola: Tax authority establishes transfer pricing unit
On September 25, 2017, the Ministry of Finance issued the order no. 678/17 establishing the Transfer Pricing Unit (TPU) to ensure and control compliance with the requirement to submit transfer pricing documents. In addition to ensuring and
See MoreUnited States: IRS issues draft advance pricing agreement (APA) template for public comment
The US Internal Revenue Service (IRS) has recently published on its web page that the IRS’s Advance Pricing and Mutual Agreement Program (APMA) is soliciting comments on a proposed revision to the template for advance pricing agreements (APAs).
See MoreDominican 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
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