Puerto Rico proposes transfer pricing rules
The Department of Treasury has released proposed regulations on 19 November 2016 regarding section 1040.09 of the Puerto Rico Internal Revenue Code of 2011. The proposal highlights US transfer pricing rules and guidelines from the Organization for
See MoreSingapore: Detailed guidance on MAP for DTAs
The Inland Revenue Authority of Singapore introduced new guidance on the mutual agreement procedure (MAP) on 12 January 2017. The guidance has provided detail procedures for the MAP. According to new guidance, the MAP will be available to those
See MoreMalta: IRD issues Guidelines on use of Mutual Agreement Procedure
The Inland Revenue Department of Malta issued guidelines for the use of the Mutual Agreement Procedure under the provisions of Article 96(2) of the Income Tax Act (ITA), on 15 December 2016. The procedure permits the Malta Competent Authority to
See MoreChile: Announcement on entry into force of new tax regime
The Tax Administration of Chile announced on 5th January 2017 that a new tax regime enters into force from 1st January 2017 as introduced by the 2014 Tax Reform. Companies under the attributed income regime have to pay first category tax at a
See MoreSpain: Government approves CbC reporting form
The country-by-country (CbC) reporting form 231 approved on 30 December 2016 in an order no. HFP/1978/2016 of 28 December 2016. The CbC report must be submitted by a company resident in Spain that is the parent company of a corporate group for the
See MoreBrazil: Regulation on CbC reporting
Normative Instruction 1,681/2016 was issued in the Official Gazette on 29 December 2016 regarding annual country-by-country (CbC) reporting. According to Normative Instruction 1,681/2016: Legal entities resident in Brazil are obliged to
See MorePeru :Amendments to Transfer Pricing rules
In Peru, Law Decree No. 1312 was published on 31 December 2016. The Decree amended the existing Transfer pricing reporting requirement by accepting the proposed changes by the Organization for Economic Cooperation and Development (OECD) within the
See MoreAzerbaijan-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
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