Pakistan: 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
See MoreUkraine: SFS clarifies the definition of related parties for the recognition of controlled transactions
On 16 May 2017, the State Fiscal Service of Ukraine published a letter No. 9012/6/99-99-15-02-02-15 concerning the definition of related parties for the recognition of transactions controlled and guided by article 52 of the Tax Code of Ukraine. The
See MoreBrazil: Additional guidance on CbC reporting rules issued
Normative Ruling 1,709/2017 of 25 May 2017 amended the 2016 normative ruling that introduced the country-by-country (CbC) reporting obligation in Brazil effective from fiscal year(FY) 2016. According to the new ruling for FY 2016, the Brazilian tax
See MoreIsrael: Status updates of automatic exchange of country-by-country (CbC) reports
The Israel Tax Authority declared the signing of a multilateral agreement for the automatic exchange of country-by-country (CbC) reports and of common reporting standard (CRS) information. The Director of tax authority signed the Multilateral
See MoreIceland issues revised bill for the CbCR
Regulation no. 1166/2016 on the documentation for CbCR (Country-by-Country Reporting) has been further revised by regulation no. 245/2017 on 24 March 2017. The revised regulation is effective on or after 24 March 2017. The revision incorporates two
See MoreHungary: CbC reporting requirements adopted
Hungary released a draft law on country-by-country (CbC) reporting on 10 March 2017 which became effective 15 May 2017. As a result, Hungary fulfilled the harmonisation requirement set by Council Directive (EU) 2016/88) and implemented the
See MoreSlovenia: Proposal for more specific requirements for CbC reporting
The Slovenian Ministry of Finance on 19 April 2017 issued a proposal to amend the rules for the application of the Tax Procedures Act. The proposal provides more specific requirements for CbC reporting. In addition the proposal would introduce CbC
See MoreIndia: Latest update on country-by-country reporting
India has recently 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 first round of CbC reports, if applicable, must be submitted to the
See MoreSingapore: 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
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