Belgium 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
See MoreRussia submits draft law on automatic international exchange of tax information including documentation requirements
The Russian Government on 20 July 2017, submitted the draft bill (Bill No. 231414-7) on the automatic international exchange of tax information to the Russian State Duma. The draft bill proposes amendments to the Tax Code, which are necessary for
See MoreIndia introduces CbC reporting requirements
India has included a country-by-country (CbC) reporting requirement in section 286 of the Indian Income-tax Act, 1961, with effect from the financial year 2016-2017. The requirements are principally in line with BEPS Action 13. The first round of
See MoreIreland publishes MAP guidelines
On 1 August 2017, Irish Revenue published a guidance on the operation of Mutual Agreement Procedure (MAP) is contained in Tax and Duty Manual Part 35-02-08. The purpose of this guidance is to set out the process through which taxpayers can request
See MoreIreland updates transfer pricing documentation obligations
On 3 August 2017, Irish Revenue published a Tax and Duty Manual Part 35a-01-02 dealing with Transfer Pricing Documentation Obligations. The contents of this manual were previously included in Tax Briefing 07 of
See MoreTransfer Pricing Brief: July 2017
Poland: Financial services-Restriction on interest deduction: According to draft bill revising on corporate income tax act published on 12 July 2017, thin capitalization rules limiting the deduction of financing costs to 30% of an adjusted tax
See MoreIsrael: District Court makes a decision on Israeli transfer pricing rules
A decision was made and governed by an Israeli District Court that when an Israeli company gained IP ownership and shortly thereafter its employees and other assets (with IP) to a related party, the transfer should be counted as a sale for whole
See MoreGermany publishes revised guidance on CbC reporting requirements
The Germany Federal Ministry of Finance (MoF) on 11 July 2017 issued guidance on the Country-by-Country (CbC) reporting requirements in line with BEPS Action 13 and the EU Administrative Assistance Directive as amended. If certain requirements are
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