Australia releases guidance on related-party marketing hubs
On 16 January 2017, the Australian Taxation Office (ATO) issued a Practical Compliance Guideline which sets out the ATO's compliance approach to transfer pricing issues related to the location and relocation of certain business activities and
See MoreAustralia releases Q&A of CbC reporting
The Australian Taxation Office (ATO) released a guidance in the form of questions and answers (Q&As) in respect of compliance with country-by-country (CbC) reporting requirements. The guidance reflects the transitional administrative practice of
See MoreColombia: Tax administrative summary of tax reform 2016
According to law 1819 of 2016, adopting the structural tax reform bill approved on 23 December 2016, which introduces the following major changes to the tax administration, tax procedures and penalties: Tax administration The tax reform introduces
See MoreOECD: Platform for Collaboration on Tax releases draft toolkit on comparables
On 24 January 2017 the Platform for Collaboration on Tax released a draft toolkit on comparables. The toolkit is designed to assist developing countries to manage situations where there is a lack of comparable transactions for use in transfer
See MoreMalaysia: IRBM issues rules on country-by-country reporting rules (CbCR Rules)
The Inland Revenue Board of Malaysia issued the income tax (Country-by-Country Reporting) rules (“CbCR Rules”) on 23 December 2016 which came into effect on 1 January 2017. The CbC rules apply to Malaysian-parented multinational corporate groups
See MoreMalaysia: Penalty for failure to furnish country-by-country report (CbCR)
The Finance Act 2016, which was gazetted on 16 January 2017, introduced penalty provision for failure to furnish country-by-country report. A new Section 112A of the Income Tax Act 1967 is introduced to address the implications on person who fails
See MoreSlovenia publishes CbC reporting guidelines
The Slovenian Financial Administration published a new guidance on the implementation of country-by-country (CbC) reporting on 12 January 2017. The new guidelines included in Action 13 of the OECD Action Plan on Base Erosion and Profit Shifting and
See MoreUS: IRS release guidance on country-by-country report filing process
The US Internal Revenue Service (IRS) issued Revenue Procedure 2017-23 on 19 January 2017 describing the process for filing Form 8975, Country-byCountry Report, and accompanying Schedules A, Tax Jurisdiction and Constituent Entity Information
See MoreBrazil issues tax regulation program
Provisional Measure 766 has issued and released on 4 January 2017. This provisional measure establishes a tax regulation program for Brazilian taxpayers to settle their tax liabilities. Under this program, taxpayers can resolve their federal tax
See MoreIsle of Man: New regulations for accounting records
On 20 January 2017, the income tax regulations 2016 come into effect for accounts and financial records and in accordance with this regulation taxpayers are required to store accounts and financial records for at least 5 years. Non-compliance with
See MoreIndia: Loss making company couldn’t be excluded from comparable list if it satisfies comparability analysis
The Ahmedabad Bench of Income-tax Appellate Tribunal in case of: Erhardt+Leimer (India) Private Limited v. ACIT (ITA Nos. 3298/Ahd/2011 & 2880/Ahd/2012) held that consistent loss-making companies cannot be rejected as comparable unless the
See MorePuerto Rico proposes transfer pricing rules
The Department of Treasury has released proposed regulations on 19 November 2016 regarding section 1040.09 of the Puerto Rico Internal Revenue Code of 2011. The proposal highlights US transfer pricing rules and guidelines from the Organization for
See MoreSingapore: Detailed guidance on MAP for DTAs
The Inland Revenue Authority of Singapore introduced new guidance on the mutual agreement procedure (MAP) on 12 January 2017. The guidance has provided detail procedures for the MAP. According to new guidance, the MAP will be available to those
See MoreMalta: IRD issues Guidelines on use of Mutual Agreement Procedure
The Inland Revenue Department of Malta issued guidelines for the use of the Mutual Agreement Procedure under the provisions of Article 96(2) of the Income Tax Act (ITA), on 15 December 2016. The procedure permits the Malta Competent Authority to
See MoreChile: Announcement on entry into force of new tax regime
The Tax Administration of Chile announced on 5th January 2017 that a new tax regime enters into force from 1st January 2017 as introduced by the 2014 Tax Reform. Companies under the attributed income regime have to pay first category tax at a
See MoreSpain: Government approves CbC reporting form
The country-by-country (CbC) reporting form 231 approved on 30 December 2016 in an order no. HFP/1978/2016 of 28 December 2016. The CbC report must be submitted by a company resident in Spain that is the parent company of a corporate group for the
See MoreBrazil: Regulation on CbC reporting
Normative Instruction 1,681/2016 was issued in the Official Gazette on 29 December 2016 regarding annual country-by-country (CbC) reporting. According to Normative Instruction 1,681/2016: Legal entities resident in Brazil are obliged to
See MorePeru :Amendments to Transfer Pricing rules
In Peru, Law Decree No. 1312 was published on 31 December 2016. The Decree amended the existing Transfer pricing reporting requirement by accepting the proposed changes by the Organization for Economic Cooperation and Development (OECD) within the
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