US: 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
See MorePakistan: Proposes documentation and CbC reporting requirements
On June 5, 2017, Pakistan's Federal Board of Revenue has presented a notification (Notification SRO 421 (I) / 2017) regarding Documentation and country-by-country reporting requirements in respect of transfer pricing. The proposed requirements are
See MoreIndia: CBDT notifies new safe harbour regime for cross-border transactions
The Central Board of Direct Taxes (CBDT) on 7 June 2017, has issued a new, relaxed, safe harbour regime in order to reduce transfer pricing disputes. The move is aimed at providing certainty to taxpayers, aligning safe harbour margins with industry
See MoreTurkey signs CRS Multilateral Competent Authority Agreement
Turkey has signed Common Reporting Multilateral Competent Authority Agreement (CRS MCAA) for the implementation of automatic exchange of financial account information pursuant to the OECD/G20 Common Reporting Standard (CRS) to launch exchanges in
See MoreNetherlands: Bill on country-by-country reporting gazetted
The lower house of the Dutch parliament adopted a bill implementing EU directive 2016/881, mandating the automatic exchange of country-by-country reporting information among EU member states on 26th April 2017. On 2nd June 2017, EU directive
See MorePakistan: FBR proposes to introduce a Directorate General of Transfer pricing
Federal Board of Revenue (FBR) has proposed through Finance Bill 2017 to establish Directorate General of Transfer Pricing which shall consist of a Director General and as many Directors, Additional Directors, Deputy Directors, Assistant Directors
See MoreRomania: Country-by-Country reporting requirement modified
The Romanian Ministry of Finance published a draft law on 24 May 2017 to modify the CbC reporting legislation of the country. According to the draft law, all Romanian tax resident entities which are ultimate parent of an MNE Group with annual
See MoreSouth Africa and U.S. sign an agreement on the exchange of country-by-country reports
The competent authorities of South Africa and the U.S. have concluded an arrangement on the exchange of Country-by-Country Reports. On June 5, 2017 the South African Revenue Service (SARS) released the text of the arrangement. According to SARS the
See MoreTurkey: Council of Minister proposes transfer pricing provisions
A draft Communique regarding transfer pricing has been published in Turkey. It generally represents measures of the OECD’s base erosion and profit shifting (BEPS) Action 13 on country-by-country reporting and transfer pricing documentation. The
See MoreTransfer Pricing Brief: May 2017
Italy: Requirement-Rule: According to Decree No.50 published on 24 April 2017, the definition of normal value with the concept of arm’s length will be modified to be more aligned with Organisation for Economic Co-operation and Development
See MoreLithuania: Parliament approves CbC reporting requirements
The Lithuanian Parliament on 23 May 2017, passed amendments to the Tax Administration Law to implement the CbC reporting requirements that will take effect from 5 June 2017. According to law, all Lithuanian tax resident entities that are part of an
See MoreMalaysia: IRBM issues amended tax audit framework for 2017
The Inland Revenue Board of Malaysia (IRBM) issued an amended tax audit framework on 1 May 2017. The aim the amended framework is to ensure that tax audits are carried out in a fair, transparent and impartial manner. The framework outlines the
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