Switzerland clarifies procedure for recovery of interest paid
The Federal Finance Department has explained the refund procedure regarding the recovery of interest paid for late reporting of intra-group dividend distributions on 1 February 2017. The explanation results from revisions of the procedure for
See MoreIndia: Proposes amendments to the transfer pricing regulations
Indian Finance Minister published India’s 2017-18 budget on 1 February 2017. Along with other measures, the budget has proposed following important amendments to the provisions of transfer pricing (TP) regulations of India: –A major proposal in
See MoreTransfer Pricing Brief: January 2017
Azerbaijan: Transfer pricing rules: Law No. 454-VQD of 16 December 2016 establishes new transfer pricing (TP) rules for certain transactions. The new TP rules cover transactions whose total value exceeds AZN 500,000 (approximately USD 278,000) in
See MoreSingapore: IRS publishes Transfer pricing guidelines 2017
The Inland Revenue Authority of Singapore published the 4th version of transfer pricing guidelines on 12 January 2017, demonstrating compliance with international transfer pricing standards. The published guidelines explicitly refer to the Base
See More7 more countries sign tax co-operation agreement to enable BEPS Action 13
According to a press release of 27 January 2017, published by the OECD, as part of continuing efforts to boost transparency by multinational enterprises (MNEs), Gabon, Hungary, Indonesia, Lithuania, Malta, Mauritius and the Russian Federation have
See MoreNigeria: FIRS issues new TP declaration and disclosure forms
The Federal Inland Revenue Service (FIRS) of Nigeria published new transfer pricing (TP) forms (TP Declaration Form and TP Disclosure Form). This is aimed at improving disclosure and transparency by taxpayers in their TP Returns, and providing FIRS
See MoreEcuador introduces new TP regulations to exports
The Internal Revenue Service of Ecuador has issued a Resolution that was published in the official gazette on 30 December 2016. The Resolution launches transfer pricing (TP) regulations applicable to exports of bananas, oil, petrol, gold, silver,
See MoreAustralia 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
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