Singapore: Cost-plus mark-up method for routine service provider companies
The Inland Revenue of Singapore has recently clarified its practice that allows service providers companies which provide "routine support services" to adopt the cost-plus mark-up method. The routine support services are such that service companies
See MoreBelgium: New CbC reporting forms and guidelines
On 19 May 2017, the Belgian Federal Public Service for Finance issued new country-by-country (CbC), local file and master file forms along with guidelines to file CbC reports under BEPS Action 13. The report submission deadline was 31 December 2016,
See MoreAustralia: Practical Compliance Guideline – cross-border related party financing arrangements and related transactions
On 16 May 2017, the Australian Tax Office (ATO) released a draft Practical Compliance Guideline that sets out the compliance approach for cross-border related party financing arrangements as defined in section 995-1 of the Income Tax Assessment
See MoreUK: Draft legislation – Corporate Interest Restriction
The Corporate Interest Restriction (CIR) legislation was included in Schedule 10 of Finance Bill 2017 but has now been removed. There has been no policy change and the government has announced it will legislate for the provisions at the earliest
See MoreKorea: Country-by-Country reporting requirements and transfer pricing rules updated
The Tax Authority of Korea introduced new forms for country-by-country (CbC) reporting and for the advance notification for recognizing the company of a multinational group as the “reporting entity.” A Master file as well as a Local file will
See MoreCroatia publishes the guidance on Advance Pricing Agreements (APAs)
The Minister of Finance, pursuant to Article 14a of the Law on Profit Tax, has issued the ordinance on the procedure for concluding the previous transfer pricing agreement. The ordinance was published in the Official Gazette No. 42/17 on 3 May 2017
See MoreSpain publishes new form for reporting related-party and tax haven transactions
Spain’s Tax Agency has recently published a draft order approving Form 232 for reporting related-party transactions and transactions and situations that involve countries and territories considered to be tax havens. The deadline for filing Form
See MoreFrance: CbC reporting notification and filing obligation
The country reporting (CbC) obligation in France contains a notification according to which French companies subject to the notification obligation are required to mention in their annual corporation tax returns, whether they will be submitting the
See MoreColombia: DIAN clarifies TP filing obligations under BEPS Action 13
On 3 May 2017, the Colombian Tax Authority (DIAN) clarified the fiscal years for which the new transfer pricing obligations established in Article 108 of Law 1819 of 2016 will apply. According to Law 1819, taxpayers have to file a local file, master
See MoreItaly: Decree issued on urgent measures on tax matters
The Council of Ministers of Italy enacted a Law Decree No.50 with an effort to meet the European Union (EU) demands of extra budget deficit cuts. The Decree was published in the Official Gazette on 24 April 2017 and provides urgent measures on tax
See MoreRussia: Publishes the draft law on CbC reporting requirements for multinationals corporate groups
The Russian government on 6 March 2017, published an amended draft law providing for new provisions on the international automatic exchange of financial accounting information for the Russian fiscal regulation and for setting new standards for the
See MoreCroatia: CbC reporting requirements implemented
The BEPS Action 13 (Transfer Pricing Documentation and Country-by-Country Reporting) has now been fully implemented in Croatia, with the full legal framework in place. The Croatian Tax Office published the CbC reporting requirements in late March
See MoreGreece: Guidelines for implementing MAP
The Public Revenue Authority has presented guidelines via POL 1049/2017 in relation to implementation of the Mutual Agreement Procedure (“MAP”). The Guidelines give detail on the provisions recently introduced in the tax code. According to the
See MoreUkraine: Cabinet of Ministers adopts the changes to advance pricing agreements
The Cabinet of Ministers of Ukraine on March 29, 2017 adopted amendments to the Regulation No. 504 of 17 July 2015 regarding the procedure of issuing advance pricing agreements (APAs). According to the adopted amendments to the Regulation No. 504 of
See MoreTransfer Pricing Brief: April 2017
China: Adjustments-MAP: Bulletin 6 governs MAP in relation to bilateral/multilateral APAs and special tax adjustments in one jurisdiction which would result in corresponding adjustment in another jurisdiction. According to Bulletin 6, the SAT may
See MoreCzech Republic: MoF issues a paper on anti-tax avoidance rules
The Finance Ministry published on its website a discussion paper regarding the implementation of EU Anti-Tax Avoidance Directive on 12th of July 2016. The directive mainly states new rules for interest deduction restrictions and similar expenses
See MoreAustralia publishes CbC reporting, Local and Master files detailed design
The Australian Taxation Office (ATO) has published a Local file / Master file detailed design to serve as guidance for taxpayers regarding the practicalities in completing country-by-country (CbC) reporting by significant global entities. ATO has
See MoreNetherlands: Parliament adopted new Bill on CbC reporting requirement
The Dutch lower house of Parliament adopted the Bill No.34651 to implement country-by-country (CbC) reporting on April 18, 2017. The bill allowed a group entity to serve as the reporting entity and a designated Dutch group entity to file an
See More