Azerbaijan-Published amendments to the Tax Code related to Transfer Pricing rules
The new amendments to the Azerbaijani Tax Code were published on 25 December 2016. The amendments introduced new Transfer Pricing provisions to the Tax Code. These amendments are effective from 1 January 2017. According to the new rules taxes may
See MoreTurkey: Bilateral APA signed
The Revenue Administration stated on 30th December 2016 that it had signed a new bilateral advance pricing agreement and this agreement is based on article 13 of Corporate Income Tax Law No.
See MoreTransfer Pricing Brief: December 2016
Norway: BEPS related compliance General rule for Country by Country (CbC) reporting: Norway has introduced Country-by-Country (CbC) reporting requirement for domestic entities with an annual consolidated group revenue of NOK 6.5 billion
See MoreLuxembourg: Tax authorities issued transfer pricing circular
The Luxembourg tax authorities issued a new circular addressing the tax treatment of companies engaged in intra-group financing transactions. On 27 December 2016, Circular L.I.R. n°56/1 – 56bis/1 is released which replaces and supersedes the
See MoreMexico issued transfer pricing adjustment rule
Mexican tax authorities has been issued rule 3.9.1 of the Miscellaneous Rule on 8 December 2016 regarding transfer pricing adjustments.The rule establishes that all transfer pricing adjustments should be reflected in the tax return in which the
See MoreCanada: Final legislation on implementation of CbC reporting requirements
Bill C-29 was passed by the House of Commons on 15th December 2016. The Bill provides the final legislation to implement country-by-country (CbC) reporting. The final legislation formalizes the introduction of section 233.8 to the Income Tax Act,
See MoreKorea- proposed changes to the country-by-country reporting requirements
The Ministry of Strategy and Finance of South Korea published a proposal for detailed procedures of the country -by country reporting requirements on 28 December 2016. The proposal requires the provision of a full report on cross-border transactions
See MorePoland: Amendments regarding TP documentation come into effect
Corporate Income Tax Law amendments gazetted in the Official Journal 1932/2015 regarding transfer pricing (TP) reporting obligations in line with Action 13 of the OECD Base Erosion and Profit Shifting (BEPS) project came into effect on 1 January
See MoreSouth Africa: SARS issues final regulations on country-by-country (CbC) reporting
The South African Revenue Service has issued final regulations on country-by-country (CbC) reporting on 23 December 2016. The regulations specify the changes to the Country-by-Country Reporting Standard for Multinational Enterprises (“MNEs”)
See MorePakistan: FBR Publishes Audit policy 2016
The new Audit Policy 2016, approved by the Federal Board of Revenue (FBR) on 3 January 2017 for selection of taxpayers for audit, would also include those cases in the parametric selection process which were earlier selected for audit last year.
See MoreIceland: Ministry of Finance publishes regulation on country-by-country reporting
The Ministry of Finance and the Economy published Regulation No. 1166/2016 on the submission of country-by-country reports (CbC) on 22 December 2016. Under the article 3 of the regulation, Iceland’s parent company resident need to submit a CbC
See MoreBelgium: CbC reporting deadline extended
The Federal Public Service of Belgium declared an extension of the deadline until 30 September 2017 to inform the tax administration that the parent corporation will file a consolidated country by country (CbC) report for the year 2016 in another
See MoreChile: CbC reporting implemented
The Tax Authority of Chile published Resolution 126 on 27th December 2016 to implement country-by-country (CbC) reporting. It requires specific taxpayers to submit an annual report to the tax authority disclosing the level of income, profit or
See MoreChina published a report of APAs 2015
On 23 December 2016, Chinese State Administration of Taxation published the Advance Pricing Agreement (APA) Report of 2015. This report of 2015 contains statistics of APAs that China concluded from 2005 to 2015. China has concluded 6 bilateral and 6
See MoreCzech Republic: Bill introducing CbC reporting submitted to parliament
The government of Czech Republic has submitted a bill on 22nd December 2016 to the parliament, which, if approved, would announce changes to the Law on International Cooperation in the Administration of Taxes. It would implement the provisions
See MoreLuxembourg: Parliament adopts country-by-country reporting
The Luxembourg Parliament on 13 December 2016 passed legislation implementing country- by-country (CbC) reporting requirements for Luxembourg entities that are part of a Multinational Enterprise Group (MNE Group). The new CbC reporting legislation
See MoreHong Kong: IRD released country-by-country reporting
The Inland Revenue Department on 22 December 2016 published on its website an announcement on country-by-country (CbC) reporting. The CbC report requires aggregate tax jurisdiction-wide information relating to the global allocation of the income,
See MoreSingapore- Voluntary filing of CbC Reports for Singaporean tax resident MNE groups for fiscal year 2016
The Inland Revenue Authority of Singapore (IRAS) announced on 19 December 2016 that the voluntary filings for Singaporean multinational enterprise groups for financial year 2016 will be allowed and this follows the e-tax guide of the
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