Cyprus: Council of Ministers approves Multilateral Instrument signing to OECD
According to a press release issued by the Finance Ministry, the signing of the “Multilateral Instrument” has been approved by the Council of Ministers on April 5, 2017. Therefore, Cyprus is going to sign the ‘Multilateral Convention to
See MoreMexico publishes final report for country-by-country reporting
Mexico’s Taxpayer Office published a final report regarding master file, local file and country-by-country (CbC) report under Article 76-A of the Income Tax Law on April 3, 2017. These documentation requirements became effective on January 1,
See MoreChina issues new TP and MAP rules
On 1 April 2017, The State Administration of Taxation (SAT) of China published a Bulletin-6 providing new transfer pricing (TP) guidance and strengthening the Mutual Agreement Procedure (MAP) process. Bulletin 6 is effective from 1 May
See MoreTransfer Pricing Brief: March 2017
Canada: General rule for CbC reporting requirement: The Canada Revenue Agency (CRA) updated RC4651 Guidance on Country-By-Country (CbC) Reporting on 2 March 2017 to provide information on the interpretation of Canadian CbC reporting legislation
See MoreUK: Amendments to CbC reporting 2017
The United Kingdom was one of the first countries to formally commit to introducing CbC reporting and the detailed implementation was given effect through the 2016 Regulations. Since the UK introduced these regulations in February 2016, the
See MorePoland: Important tax changes for 2017
A number of major tax changes have been introduced as of 1 January 2017. The changes are given below: Personal income tax: Personal income tax has a major change on the tax-free amount that is based on the tax base. In accordance with the new
See MoreUkraine: State Fiscal Service clarifies contribution of fixed assets to share capital
Contribution of fixed assets to the share capital of an Ukrainian company is treated as a controlled transaction for transfer pricing purposes. On 9 March 2017, the State Fiscal Service (SFS) clarified this through issuing Guidance Letter No.
See MoreBulgaria: Proposed bill about CbC reporting requirements published
The Finance Ministry has published a revised draft bill on 21st March 2017 that amends the Tax and Social Security Procedure Code (TSSPC) with regard to the new country-by-country (CbC) reporting requirements. It is proposed that the amendments will
See MoreUS: IRS releases annual report on advance pricing and mutual agreement program for 2016
The IRS has issued its annual report on advance pricing agreements (APAs) and the Advance Pricing and Mutual Agreement (APMA) Program (formerly the Advance Pricing Agreement (APA) Program). The report was issued as IRS Announcement 2017-3 dated 27
See MoreIceland updates regulation on CbC reporting
The Ministry of Finance and Economic Affairs issued Regulation No. 245/2017 amending Regulation No. 1166/2016 regarding country-by-country (CbC) reporting on 24 March 2017. The amendment aligns the wording of article 4 of the model provision related
See MoreNetherlands amendments to bill on country-by-country reporting
The State Secretary for Finance has submitted an amended bill to the lower house of the parliament regarding country-by-country reporting on 21 March 2017. The bill implementing Council Directive (EU) 2016/881 of 25 May 2016 amending Directive
See MoreTurkey: Announcement of unilateral APA signed
The Tax Administration of Turkey declared an announcement on 20th March 2017 that it had signed a new unilateral Advance Pricing Agreement (APA) on 1st March 2017. The APA is prepared on the basis of article 13 of Corporate Tax Law No.
See MoreUkraine: State Fiscal Service clarifies usage of information for transfer pricing purposes
The State Fiscal Service (SFS) recently published Guidance Letter No. 517/Г/99-99-12-03-07-14 of 16 January 2017, the State Fiscal Service (SFS) clarified which sources of information should be used for transfer pricing purposes according to the
See MoreUkraine: State Fiscal Service clarifies procedure for transfer pricing adjustments
The State Fiscal Service (SFS) on 4 January 2017 issued Guidance Letter No. 29/6/99-99-15-02-02-15 clarifying the procedure for transfer pricing adjustments by corporate income taxpayers that are required to file quarterly returns. According to tax
See MoreItaly-Ministerial Decree implementing Country-by-Country Reporting issued
The Italian Ministry of Finance issued a Decree on 8 March 2017 providing detailed information regarding the application of CbC reporting rules. The Decree is in accordance with an EU Directive of 25 May 2016 requiring all EU Member States to
See MoreVietnam: Recently released a new transfer pricing decree
Vietnam’s Government has recently released a Transfer Pricing (“TP”) Decree No. 20/2017/ND-CP on 24 February 2017, provided that tax administration applicable to enterprises having controlled transactions’ (Decree 20), which will take effect
See MoreIndia: Delhi High Court removed the penalty assessment for related-party transactions
The Delhi High Court, in the case of: Pr.CIT v. Mitsui Prime Advanced Composites India Pvt. Ltd. (ITA 913/2016, CM APPL.46519/2016), dismissing tax department’s appeal and upheld the Tribunal’s order deleting penalty under Section 271(1)(c) of
See MoreChina concludes first cost sharing agreement APA
The State Administration of Taxation (SAT) of China recently concluded the first advance pricing agreement (APA) for a cost sharing agreement (CSA) with a Fortune 500 enterprise in Guangdong Province. The CSA-APA focuses on international R&D
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