Hungary: 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
See MoreTransfer Pricing Brief: August 2016
Greece: Documentation requirement: As per the bill approved by the Ministry of Finance on 27 July 2016, the General Secretary of Public Revenue may exempt very small enterprises from the submission of transfer pricing documentation. Documentation
See MoreUK: Large Business Survey 2015
On 25 August 2016 HMRC published the Large Business Survey 2015. The survey asked large businesses about various aspects of their relationship with HMRC. A telephone survey was conducted with 932 Heads of Tax and Directors of Finance of large
See MoreTurkey: Amendment in transfer pricing legislation
The Law No. 6728 on the amendment of certain laws for the improvement of the investment landscape has been published in the Official Gazette on 9 August 2016. This law amended certain transfer pricing provisions. Some of the provisions are given
See MoreColombian National Tax Authority reminds procedure for filing TP informative return
DIAN reminded that the formal obligation to file an informative return will only be complied with if the transfer pricing informative return (Form 120) is digitally signed and submitted and as such mere submission of Form 1125 to DIAN through its
See MoreIsrael: CbC reporting, transfer pricing documentation in budget plan
The Ministry of Finance’s budget plan for 2017-2018 has been approved by the Israeli government on 12th August 2016 that includes tax legislative measures. This budget plan covers: CbC reporting requirement: General rule: The Israeli budget plan
See MoreSouth Africa: SARS published Transfer Pricing documentation proposal for public comments
The South African tax authorities published for public comments a Draft Notice on additional Transfer Pricing record-keeping requirements. Where a person has entered into a potentially affected transaction, the aggregate of the transaction for the
See MoreUkraine: Tax authorities defines the controlled transaction
Recently the Ukrainian tax authorities issued a Guidance Letter No. 14491/6/99-99-15-02-02-15 regarding transactions with related non-residents of Ukraine, and transactions with residents of low-tax jurisdictions and sales of goods through a
See MoreUK: Consultation on tax simplification for unincorporated businesses
On 15 August 2016 HMRC published a consultation document on simplifying tax for unincorporated business. The UK government announced at Budget 2016 that it would be looking at simplifying tax rules for businesses, with a focus on the self employed
See MoreLuxembourg: Government submitted draft law on CbC reporting to the Luxembourg Parliament
Recently the Luxembourg Government submitted draft law n°7031 on country by country (CbC) reporting to the Luxembourg Parliament. The draft law is in accordance with a European Union (EU) Directive of 25 May 2016 requiring all EU Member States
See MoreUruguay-Bill on adoption of CbC reporting, Master file documentation and the availability of bilateral and multilateral APAs
The Uruguay Government has submitted to Congress a tax bill including adoption of the OECD’s recommendations for Country-by-Country (CbC) reporting following the scope of information to be provided under the Base Erosion and Profit Shifting (BEPS)
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