France: list of cooperating jurisdictions on CbC reporting requirement published
A list of jurisdictions that have introduced Country-by-Country reporting requirements and have concluded a competent authority agreement on the automatic exchange of CbC reports with France was published in the French Official Journal on 8 July
See MoreSlovenia publishes detailed rules on CbC reporting
The Slovenian government on 16 June 2017 published the regulation on country-by-country (CbC) reporting in the Official Gazette (No. 30/2017) which came into force on 29 June 2017. The Regulation provides a more detailed description of the rules on
See MoreOECD: Draft 2017 updates to the Model Tax Convention
On 11 July 2017 the OECD issued the draft 2017 update of the OECD Model Tax Convention. The changes are to be submitted later in 2017 for approval by the Committee on Fiscal Affairs and the OECD Council. Some parts of the update relate to the
See MoreSingapore: draft transfer pricing legislation proposed
According to the draft Income Tax (Amendment) Bill 2017 (Draft Bill) proposed on 19 June 2017, section 34D of the Singapore Income Tax Act (SITA) would be expanded to provide clarification on the meaning of arm’s-length conditions. The proposed
See MoreRomania: Country-by country reporting requirements implemented
The Romanian Government passed Emergency Ordinance no. 42/2017 on 9 June 2017 to implement country-by-country (CbC) reporting requirements in Romania, transposing the provisions of Directive (EU) 2016/881 dated 25 May 2016 into the national
See MoreOECD: 2017 edition of the transfer pricing guidelines issued
On 10 July 2017 the OECD issued the 2017 edition of the OECD transfer pricing guidelines. The amendments made in the latest edition of the guidelines mainly arise from the transfer pricing aspects of the conclusions and recommendations of the
See MoreSri Lanka: New law to revise TP penalties
According to new tax law Sri Lanka, corporate that violate transfer pricing (TP) rules can be fined up to 2% of the total amount of transactions between related parties. The new law also contains the provision to impose a penalty of up to 1% of the
See MoreVietnam publishes guidance on new transfer pricing requirements
The Ministry of Finance on 22 June 2017 published Circular 41/2017 / TT-BTC (28 April 2017), which provides some guidelines for the application of Decree No 20/2017 and this Circular will take effect on 1 May 2017. Circular 41/2017 introduced some
See MoreOECD: Comments received on draft HTVI implementation guidance
On 5 July 2017 the OECD published comments received in relation to the BEPS discussion draft on the implementation guidance on Hard-to-Value Intangibles (HTVIs). The comments received focus on a range of points including the uncertainty arising for
See MoreTransfer Pricing Brief: June 2017
Greece: Main corporate tax rate: According to Law 4472/2017 published in the official Gazette on 19th May 2017, the corporate income tax (CIT) rate will be reduced from 29% to 26% from 1 January 2019 subject to certain conditions. See the story
See MoreSouth Africa: SARS issues country by country reporting, master file and local file guidance
On 23 June 2017, the South African Revenue Service (SARS) released an external Business Requirements Specification (BRS) document concerning Country-by-Country and Financial Data reporting. The document contains the draft public notice requiring the
See MoreUS: IRS Launches CbC reporting pages on IRS.gov
The Internal Revenue Service on 30 June 2017 announced the launch of Country-by-Country Reporting pages on irs.gov. These pages provide background information on Country-by-Country Reporting, frequently asked questions and other helpful resources,
See MorePlatform for Collaboration on Tax issues toolkit on comparables
On 22 June 2017 the Platform for Collaboration on Tax (PCT) published a toolkit with guidance for developing countries on dealing with the problem of accessing appropriate comparable data when preparing a transfer pricing study. The PCT was set up
See MoreSweden: Proposal for major corporation tax reforms
The Swedish Government on 20 June 2017 issued a statement proposing important changes in the area of corporate taxation. The main proposals are summarised below: According to the announcement the deductibility of the net interest expense would
See MoreIndia: Income Tax Appellate Tribunal rejects internal comparable
The Ahmedabad Bench of Income-tax Appellate Tribunal on 24 may 2017, in the case of Inductotherm (India) Pvt. Ltd. v. DCIT held that "internal costs plus method" do not apply to benchmark exports of finished goods to a related party when there are
See MoreIndia: CBDT notifies rule for secondary adjustments in transfer pricing
The CBDT has notified a new "Income Tax Rule 10CB" which stipulates a deadline for the reimbursement of excess money (90 days) and the applicable interest rate (separate interest rates for transactions in INR / foreign currency) taken into account
See MoreCosta Rica: Tax administration temporarily suspends filing date for TP information return
The Costa Rican Tax Administration has temporarily suspended the filing date for the transfer pricing information return. On 5 June 2017 Resolution DGT-R-28-2017 was published in the Official Gazette to give effect to this measure. The resolution
See MorePortugal: CbC reporting deadline extended
The State Secretary for Fiscal Affairs of Portugal published “Dispatch No. 170/2017/XXI” on 29 May 2017, which has extended the deadline for country-by-country (“CbC”) reporting notifications for fiscal year 2016 further to 31 October
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