Spain: Tax authority announced model country-by-country reporting form
Recently the Spanish tax authorities published a communication announcing the submission of a model country-by-country (CbC) reporting form (231). The form has not yet been approved. Under the Spanish corporate income tax regulations any entity or
See MoreKorea-Tax reform bill of 2017 enacted
Korea enacted the tax reform bill of 2017 on 20 December 2016 which was approved by the National Assembly on 2 December 2016. According to the Tax Reform of 2017 domestic merged brother-sister companies would be considered as tax free if and only
See MoreUkraine-Adopted amendments to Tax Code
The parliament of Ukraine adopted a draft law amending the Tax Code on 21 December 2016. According to the adopted law, costs for repairing and maintenance of non-productive fixed assets will no longer be considered as deductible expenses. Previously
See MoreUruguay- New transfer pricing requirements for corporations with income derived from tax-exempt activities
The Tax Authority of Uruguay issued Ruling No. 5,947 on 6 December 2016 according to which a corporation conducts business with foreign related companies with income derived from a tax-exempt activity will be subject to the transfer pricing
See MoreMalta: Guidance on the use of MAP published
On 15 Dec 2016, The Commissioner for Revenue has published guidance issued under the provisions of article 96(2) of the Income Tax Act (ITA) on the use of Mutual Assistance Procedure
See MorePortugal- Extension of the deadline for filing Country-by-Country reporting notification
The Secretary of State for Tax Affairs’ Office of Portugal published Decree no.254/2016-XXI (dated 12 December 2016) on 15 December 2016 which extends the deadline to submit the mandatory Country-by-Country (CbCR) notification for the fiscal year
See MoreUS: IRS issued CBC draft form
The US Internal Revenue Service (IRS) has issued a draft of IRS Form 8975 (Country-by-Country Report) that will be used for country-by-country (CbC) reporting by the US persons that are the ultimate parent entity of a multinational enterprise (MNE)
See MoreBelgium issues TP documentation forms and instructions
During June 2016, Belgium has introduced mandatory transfer pricing documentation and country-by-country (CbC) reporting requirements in accordance with Base Erosion and Profit Shifting (BEPS) Action 13 of the Organisation for Economic Co-operation
See MoreJersey: Country-by-country reporting announced
The Taxation Regulation 2016 of Jersey regarding Country-by-country reporting has been made on 14th December 2016 and the regulations will entry into force on 21st December 2016. It covers a country-by-country (CbC) reporting obligation for
See MoreColombia: DIAN rules to keep accounting records
According to ruling 31252 of 2016, the tax authority of Colombia (DIAN) pronounced on the obligation for taxpayers to keep accounting records. Commerce Code article 19 provides that individuals and companies considered to be merchants are obliged to
See MoreIreland: CbC reporting notification deadline
On 1 January 2016, Ireland’s new Country-by-Country (CbC) reporting requirements took effect. The Irish CbC requirements require certain Irish parented groups, and in specific instances, domestic subsidiaries of foreign parented groups, to report
See MoreCyprus: Tax authority published circular on transfer pricing adjustment
The Cyprus Tax Department on 24 November 2016 issued Circular 2016/15 clarifying the application of article 33 of the Income Tax Law. Article 33 allows the tax authorities to adjust transactions between related parties on terms which, in the opinion
See MoreFrance-CbC reporting requirements conflicting to constitution
The Constitutional Court provided its decision on 8 December 2016 regarding the compatibility with the constitution of the public country-by-country (CbC) reporting requirements introduced through the bill on transparency, the fight against
See MoreCosta Rica: A discussion draft published for comments on Transfer pricing documentation guidelines
The Costa Rican Ministry of Finance published a discussion draft on 12 December 2016 on a resolution regarding guidelines on transfer pricing documentation. The requirements under the guideline set out the operations of companies within the economic
See MoreDenmark: Issues CbC notification rules
The Danish tax authorities (SKAT) on 9 December 2016 announced that country-by-country (CbC) notifications must be submitted electronically and in a standardised format on Form 05.034. The form contains instructions both in English and Danish, and
See MoreNorway: Country-by-country reporting under BEPS Action 13
Finance Minister of Norway published a regulation on country-by-country reporting legislation based on proposal under Action 13 of the BEPS Action Plan on 9 December 2016. . Norway’s CbC reporting regulation will be effective from beginning of the
See MoreTransfer Pricing Brief: November 2016
Malaysia: Penalty for non-compliance of CbC reporting: The fiscal Budget for 2016 has proposed a penalty between MYR 20,000–100,000 or imprisonment of not more than 6 months, or both, for an incorrect return or failure to comply with CbC
See MoreBrazil: Publishes proposed Country-by-Country reporting rules
The Brazilian Federal Revenue Agency on 4 November 2016, published a proposed Normative Instruction to establish country-by-country reporting (CbCR) rules in Brazil for Multinational groups where the ultimate parent company is a resident in Brazil
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