Mexico: Tax Authorities issues proposed regulations
Mexican Tax Authorities issued proposed regulations regarding the “additional information” that could be requested as part of the new transfer pricing obligations, which require Mexican taxpayers to submit a master file, local file and
See MoreSingapore-New reporting requirement of related party transactions
The Inland Revenue Authority of Singapore (IRAS) updated the transfer pricing administration information on its website regarding the reporting of related-party transactions (RPTs) on 3 November 2016. According to the new requirements a company must
See MoreFrance-New threshold for eligibility of abridged transfer pricing documentation
In France, a new law had been enacted on 8 November 2016 which provides for a reduced threshold for taxpayers to be eligible for filing the “abridged” transfer pricing documentation (Form 2257). The threshold as codified at Article 223 quinquies
See MoreHMRC Updated guidance on advance pricing agreements
On 8 November 2016, HM Revenue & Customs (HMRC) updated Statement of Practice 2 (2010) which sets out the process for obtaining advance pricing agreements (APAs). The updated statement of practice: Updates previous guidance on the
See MoreCosta Rica: Resolution on transfer pricing return procedure entered into force
Costa Rican tax authority has Gazetted the resolution N ° DGT-R-44-2016 on September 13, 2016 that regulates the transfer pricing return in Costa Rica entered in force. With the publication of resolution N ° DGT-R-44-2016, technical and practical
See MoreFinland: Government published a proposal on Country-by-country reporting
The Finnish government published a proposal to implement the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) initiative on transfer pricing documentation as well as a corresponding EU directive
See MorePanama: TP documentation requirements and Arm’s length principle
Decree 390 was published in the Official Gazette on 25 October 2016 to regulate the arm’s length principle established in the Fiscal Code and establishes Transfer Pricing documentation requirements. The Decree will enter into force on 1 January
See MoreCroatia: Proposal for corporate income tax amendments
The Tax Administration has presented proposed changes to the Corporate Income Tax Law (CIT law) on 4th November 2016. The significant elements are summarized below: Tax Base The tax base of corporate income tax will be extended by introduction of
See MoreTransfer 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
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