Transfer Pricing Brief: October 2016
Malaysia: Main Corporate tax rate: The Budget for 2017 proposed to reduce the corporate tax rate for the year of assessment 2017 and 2018. As per the proposal, the reduce tax rate will be between 1 and 4 percentage points for companies with
See MoreWorld Bank issues 2017 report on ease of doing business
On 25 October 2016 the World Bank issued the 2017 issue of the annual report on ease of doing business entitled Doing Business 2017: Equal Opportunity for All. According to the report 137 jurisdictions carried out important reforms in the past year
See MoreBulgaria: Country-by-country reporting
A bill entitled “Bill 602-1-59” has been submitted to the Bulgarian parliament. The Ministry of Finance has published a draft bill on 16th September 2016 regarding the automatic exchange of country-by-country reports (CbCR). As per the draft
See MoreEthiopia: Introduces Transfer Pricing Rules
Ethiopia has introduced Transfer Pricing rules and the new rules are applicable for all Ethiopian taxpayers with cross-border Intercompany Transactions exceeding 500,000 Ethiopian birr/USD 22,380 and for Ethiopian taxpayers with domestic
See MoreMexico: Amendments of transfer pricing rules
Mexico’s Tax Administration Service (SAT) on July 14 published two important transfer pricing rules in the Third Resolution on Amendments to the Omnibus Tax Bill for 2016. Rule No. 3.9.5 of Resolution on Amendments to the Omnibus Tax Bill for 2016
See MoreSlovak Republic: Introduction to country-by-country reporting
The legislative bodies of Slovakia has issued a bill amending Act No. 442/2012 Coll. on international assistance and cooperation in tax administration that introduces the country-by-country (CbC) reporting obligation in Slovakia. The draft
See MoreSingapore: Publishes Guidance on CbC Reporting
The Inland Revenue Authority of Singapore (IRAS) has published detailed guidance on the implementation of a new country-by-country (CbC) reporting requirement in the territory on 10 October 2016, which sets out entities are obliged to report and
See MoreTransfer Pricing Brief: September 2016
Costa Rica: Filing of annual transfer pricing return: Costa Rica has published a resolution in the official gazette to finalize the rules concerning the filing of an annual transfer pricing return for taxpayers qualifying as “large
See MoreNorway: Published proposal on Country-by-country reporting
The Norwegian Government published its proposal for the 2017 Fiscal Budget on the domestic Country-by-Country (CbC) reporting rules in line with the OECD BEPS Action 13 recommendations to the Norwegian tax authorities. As per the proposal, all
See MoreSwitzerland: Parliament adopted the final Corporate Tax Reform III
On June 17, 2016, the Swiss parliament adopted the final Corporate Tax Reform III package (CTR III) to strengthen Switzerland’s competitiveness as a business location. The Corporate Tax Reform III includes several notable tax reform measures
See MoreHungary: Introduces a new type of tax audit of binding rulings
Tax audit of binding rulings From July 1, 2016, a new type of tax audit was introduced whereas binding rulings may be fact-checked by the tax authority. The tax authority may start this type of audit regarding a taxpayer’s past tax years to find
See MoreDenmark: Publishes new executive order on country-by-country reporting
A Danish executive order No. 1133 dated 27 August 2016 was issued to provide detailed rules on notice requirements and on how the CbC report must be completed. The executive order was effective from 1 September 2016. Notification requirements: i)
See MoreCosta Rica: Tax authority finalize transfer pricing return procedures
Costa Rica has published a resolution in the official gazette to finalize the rules concerning the filing of an annual transfer pricing return for taxpayers qualifying as “large taxpayers” or as “national large companies” or operating under
See MoreUK given powers to introduce public CbC reporting
The UK Government has accepted a cross-party backbench amendment to Finance Bill 2016 which gives HM Treasury powers to introduce public country-by-country reporting. The amendment allows, but does not compel, HM Treasury to bring forward
See MoreChina: New changes of TP regulations
SAT Bulletin No. 42 published on July 13, 2016 has replaced the existing transfer pricing documentation regulations in Circular Guoshuifa No. 2, known as Circular 2. As per Bulletin 42, two parties will be considered related if they have “other
See MoreUK: HMRC survey of mid-sized businesses
n 25 August 2016 HMRC published the results of a survey of mid-sized businesses. This covers the types of business dealt with by HMRC’s Mid-Size Business Unit. These businesses are seen by HMRC as a distinct group owing to their contribution to
See MoreRussia: New version of draft law on BEPS Action 13 implementation issued
The Finance Ministry has issued a new version of the draft law on 6th September 2016 regarding BEPS Action 13 implementation. The draft law proposes the following topics: BEPS related compliance: Documentation requirement: Master file: As per the
See MoreBrazil: Private ruling published in the Official Gazette on transfer pricing resale price method
Private Ruling 63/2016 published in the Official Gazette of 31 August 2016 clarified that under the transfer pricing resale price method, the fixed profit margins apply according to the economic sector of the legal entity. In the case of resident
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