Malaysia: 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
See MoreTransfer 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
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