Norway Published a Public Consultation Paper Regarding CbC Reporting for Tax Purposes
Norway has published a public consultation paper regarding country-by country (CbC) reporting for tax purposes. As per the proposal, multinational groups when the ultimate parent company is a resident in Norway would be required to submit country-by
See MoreThe Dutch Parliament approved bill on supplementary transfer pricing documentation requirements
The Dutch Parliament approved the Other Fiscal Measures Bill that includes supplementary transfer pricing documentation requirements in order with the three tiered approach of Action 13 of the OECD Base Erosion and Profit Shifting (BEPS) project, on
See MoreTransfer Pricing Brief: December 2015
Mexico: Financial Services: Interest-accruing debts incurred in constructing, operating or maintaining production infrastructure linked to strategic areas in Mexico will not subject to the thin capitalization rules. Base Erosion and Profit
See MoreMalaysia: Thin capitalization rules deferred till 2018
The Ministry of Finance has issued a noticed on 30 December, 2015, regarding the effective date of the Income Tax (Thin Capitalization) Rules. The Rules has been deferred to till 2018 and will take effect from 1 January
See MoreSouth Africa: SARS announces to implement country-by-country reporting requirement
In line with the OECD base erosion and profit shifting (BEPS) initiative (action 13), effective 1 January 2016, South Africa Revenue Service (SARS) has announced that it will implement country-by country (CbC) reporting. The CbC report is the third
See MoreUS: Treasury and IRS Issued Proposed Regulations on Country-by-Country Reporting on 21 December 2015
The Internal Revenue Service (IRS) and the Treasury Department (Treasury) released proposed regulations (REG-109822-15) on country-by-country (CbC) reporting on 21 December 2015. The Proposed Regulations are modeled on the Organization for Economic
See MoreFrance-Approved Finance Bill 2016 and amended Finance Bill 2015
The French Parliament approved the Finance Bill for 2016 and and the amended Finance Bill for 2015 on 17 December 2015. The Finance Bill enacts the country-by-country (CbC) reporting requirement into the legislation of France. From 1 January 2016
See MoreCountry-by-country reporting is enacted in Ireland
On 22 December 2015, the president of Ireland signed into law Finance Act 2015 that includes rules following the OECD's recommended country-by-country (CbC) reporting requirements. The Finance Act provision closely mirrors the OECD’s recommended
See MoreItaly: Budget for 2016 Approved with Reduction of Corporate Tax Rate and CbC Reporting Requirement
The 2016 budget law that has now been approved includes reduction of corporate tax rate for 2017 and Country-by-Country (CbC) reporting requirements with amendments in Act n. 2111-B. The Law no. 208 of 28 December 2015 provides a reduction of the
See MoreKorea: Tax reform bill of 2016 enacted
The National Assembly of Korea passed the Tax Reform Bill of 2016 on 2 December 2015. The bill was enacted on 15 December 2015 and certain Enforcement Decrees are expected to be approved by the Government in the near future. According to the
See MoreDenmark: Government Passes bill on Country-by-Country Reporting
On 18 December 2015 the Danish Parliament approved the draft Bill introducing Country-by-Country Reporting based on Action 13 of the Organization for Economic Co-operation and Development (OECD) project on Base Erosion and Profit Shifting
See MoreGhana: New Income Tax Act from January 2016
Ghana's new Income Tax Act (No. 896 of 2015) will come into force on January 1, 2016. It is intended to improve tax compliance and administration and broaden the country's income tax base by rationalizing tax breaks. A number of significant changes
See MoreJapan: 2016 Tax Reform Outline
Japan’s ruling party released the 2016 Tax Reform outline on 16 December 2015. The Outline includes a further corporate tax rate reduction and introduction of a new transfer pricing documentation rule. A tax reform bill will be prepared based on
See MoreMexico: New requirements for documentation
Mexico has introduced transfer pricing documentation requirements for a master file and local file in line with the OECD Base Erosion and Profit Shifting (BEPS) project from 1 January 2016. It will be mandatory to prepare this information for
See MoreHungary: Tax amendments approved by parliament
The parliament of Hungary approved a bill on 17 November 2015 establishing some additional amendments to the country's current tax system. According to the approved bill a classification system will be introduced and companies will be classified as
See MoreAustralian Senate passes Government’s multinational anti tax avoidance measures
The Turnbull Government has secured the passage of the Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill, a critical piece of legislation, which will ensure major international companies operating in Australia but booking profits
See MoreTransfer Pricing Brief: November 2015
Greece: Documentation requirement: Transfer pricing documentation requirements as set out by the Income Tax Code and the Procedural Code do not apply in respect of transactions made by real estate investment companies as per the clarification
See MoreFrance adopts country-by-country reporting requirement
The lower house of the parliament in France adopted an amendment to the Finance Bill for 2016 on 12 November 2015. The amended Finance Bill introduces a country-by-country reporting requirement for multinational companies which will be applicable
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