US: IMF report looks at fiscal position
The IMF has published a Concluding Statement following the conclusion of consultations under Article IV of the IMF’s articles of agreement. The report sets out the preliminary findings of the IMF staff. The report notes that the US economy is in
See MoreRomania: DTA with Uzbekistan signed
The president of Romania signed a law ratifying the amending protocol of Double Taxation Agreement (DTA) with Uzbekistan on 8 May
See MoreCyprus: Finance Ministry issues revised decree on country-by-country reporting
On 26 May 2017 the Ministry issued a revised decree on Country-by-Country (CbC) Reporting, under the powers conferred by Section 6(16) of the Assessment and Collection of Taxes Law. The obligation of a Cyprus tax resident Constituent Entity of a
See MoreSouth Africa: SARS publishes draft notice on BEPS related compliance
On June 1, 2017, the South African Revenue Service (“SARS”) published a draft public notice requiring the submission of country-by-country (“CbC”) reports, a master file and a local file by groups with turnover above a specified
See MoreAustralia: Implementation of the OECD hybrid mismatch rules
The Government of Australia has committed to the implementation of Action Item 2 of the G20/OECD BEPS Action Plan, which recommends neutralizing the effects of hybrid mismatch arrangements that occur due to the different treatment of an entity or
See MoreFrance: CbC reporting notification and filing obligation
The country reporting (CbC) obligation in France contains a notification according to which French companies subject to the notification obligation are required to mention in their annual corporation tax returns, whether they will be submitting the
See MoreCanada: BEPS update in Federal Budget 2017
The Federal Budget 2017 will invest an extra amount of $523.9 million to develop tax compliance, prevent tax evasion and combat tax avoidance by raising verification activities, developing the excellence of investigative work focusing on criminal
See MoreCosta Rica: Tax Authority issues transfer pricing guidelines
Costa Rican tax authority on 21 April 2017, issued Resolution DGT-R-16-2017 in relation to transfer pricing documentation guidelines. The Resolution establishes requirement of taxpayers having transactions with related parties to retain supporting
See MoreUkraine updates tax code concerning transfer pricing changes
Transfer pricing legislation in Ukraine has been changed effective from January 1, 2017. The law introduces changes to the Tax Code of Ukraine with respect to transfer pricing rules (TP). The following changes have been introduced on “Amending the
See MoreNew Zealand: Finance Minister releases BEPS consultation papers
The Revenue and Finance Minister on 3 March 2017 released three BEPS related consultation papers which address the issue of Base Erosion and Profit Shifting (BEPS). The consultation papers proposed new measures to strengthen New Zealand’s rules
See MoreOECD: Guidance on implementation of the Common Reporting Standard
On 6 April 2017 the OECD released further information to support the consistent implementation of the Common Reporting Standard (CRS). This guidance includes a series of additional frequently asked questions (FAQs) related to the CRS and the second
See MoreUK: Budget proposals for 2017/18
The UK budget proposals announced on 8 March 2017 contained a number of tax changes including the following: Making tax digital The introduction of the new system of mandatory online tax returns for unincorporated businesses and landlords with
See MoreTransfer Pricing Brief: February 2017
Ukraine: Controlled transaction: As per the amended Tax Code effective from 1 January 2017, a transaction is considered controlled if the annual income of the taxpayer within the reporting period exceeds UAH 150 million, and the sum of the
See MoreCanada, Singapore Competent authority agreement on automatic exchange of information enters into force
The Competent Authority Agreement on Automatic Exchange of Information (2016) between Canada and Singapore entered into force on 27 February 2017. The agreement is expected to make sure Canada and Singapore will be able to begin from 2018, the
See MoreHong Kong: Transfer pricing proposals in 2017 budget
Hong Kong’s Financial Secretary on 22 February 2017 delivered the budget speech to the Legislative Council. In his budget speech, the Secretary mentioned the government’s plan for implementing a statutory transfer pricing regime in Hong
See MoreDenmark: Publishes new guidelines on TP documentation
The Minister of Taxation issued order BEK no. 401 and 402 regarding transfer pricing documentation. The new documentation guidelines BEK no. 402 will replace the previous guidelines of BEK no. 42. The new guidelines include more specific
See MoreBelgium adopted TP documentation
The transfer pricing documentation structure has been implemented in Belgium proposed by the Organisation for Economic Cooperation and Development (OECD). In accordance with the guidance of OECD under Action plan 13, Belgium initiated transfer
See MoreIndonesia revises TP documentation requirements
The transfer pricing (TP) documentation rules has been revised by Indonesian tax authority to match global standards and curb practices of tax avoidance. Head of the international department at the finance ministry's tax office, Mr John Hutagaol
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