Transfer Pricing Brief: July 2019

July 10, 2019

PanamaCbC reporting requirement-General rule: On 27 May 2019, Panama introduced Country-by-Country (CbC) reporting requirements for MNE’s whose consolidated group revenue exceeds €750 million. Timing: The CbC report must be filed no

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Transfer Pricing Brief: June 2019

June 03, 2019

HungaryDocumentation-Timing: On 8 May 2019, the Hungarian National Tax and Customs Administration issued a notice to remind taxpayers that they must prepare their transfer pricing documentation by 31 May 2019 if they are required to keep

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Transfer Pricing Brief: May 2019

May 08, 2019

JapanAudit Rules-Statute of limitation: On 27 March 2019, the Parliament of Japan adopted the legislation for the government's tax reform proposals for 2019. Accordingly, the statute of limitations for transfer pricing purposes is extended

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Transfer Pricing Brief: April 2019

April 04, 2019

FinlandRestriction on interest deduction: On 7 March 2019, the Finnish tax administration published new guidelines on the rules on interest deduction restrictions, which were amended to comply with EU Anti-Tax Avoidance Directive (ATAD), and

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Transfer Pricing Brief: March 2019

March 05, 2019

Hong Kong CbC reporting requirement-General rule: On 1 February 2019, Hong Kong Inland Revenue Department (IRD) announced that effective from 1 April 2019, the department will not accept voluntary filing of a CbC return for an accounting period

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Transfer Pricing Brief: February 2019

February 05, 2019

Dominican Republic Documentation-Thresholds: On 17 January 2018, Directorate General of Internal Revenue (DGII) published the Transfer pricing (TP) reporting threshold for 2019. The DGII has issued Notice 8-19, which prescribes related party

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Transfer Pricing Brief: January 2019

January 06, 2019

Costa Rica Interest limitation rule: On 4 December 2018, Costa Rica passed a tax reform bill which includes several tax reform measures. Under the law, an interest limitation rule applies which interest expenses that exceed 20% of the

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Transfer Pricing Brief: December 2018

December 05, 2018

Finland Control: On 1 November 2018, the Ministry of Finance submitted a bill to Parliament proposing changes to the CFC rules. Under the proposed rules, the control threshold setting the CFC status would be reduced from 50% to 25%, and the

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Transfer Pricing Brief: November 2018

November 05, 2018

Nigeria Documentation-Deadline: On 3 October 2018, Federal Inland Revenue Service published a notice granting taxpayers that they have until 31 December 2018 to satisfy all pending obligations pertaining to filing of TP declaration, making

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Transfer Pricing Brief: October 2018

October 07, 2018

Israel Priority of Methods: According to Circular 11/2018 published on 5 September 2018, in case of sales activity that is performed without significant marketing intangibles, the most appropriate transfer pricing method according to the ITA is

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Transfer Pricing Brief: September 2018

September 06, 2018

Australia Special rules for hybrid instruments or entities: On 16 August 2018, Treasury Laws Amendment (Tax Integrity and Other Measures No. 2) Bill 2018 containing the hybrid mismatch integrity measures was passed by the Parliament. The bill

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Transfer Pricing Brief: August 2018

August 01, 2018

Australia Rule: On 9 July 2018, ATO published draft Schedule 2 compliance guideline (PCG) 2017/1, covering ATO's compliance approach to transfer pricing issues related to centralized operational models involving procurement, marketing, sales and

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Transfer Pricing Brief: July 2018

July 01, 2018

Sweden Restriction on interest deduction: On 14 June 2018, the Parliament passed a bill regarding a general provision limiting the deductibility of net interest expense to 30% of earnings before interest, tax, depreciation and amortization

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Transfer Pricing Brief: March 2018

April 05, 2018

Hong Kong: CbC reporting requirement: On 5 March 2018, Hong Kong government announced that it has launched its country-by-country reporting portal. Hong Kong Ultimate Parent Entities of Reportable Groups (HK UPEs) can now file CbC Returns for

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Transfer Pricing Brief: February 2018

March 06, 2018

Malaysia: APAs-Fees: In December 2017, APA rules 2012 was amended by inserting a new Rule 23 which allows the MIRB to charge an application fee and any expenses as the Director General may determine in the course of the APA application. The APA

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Transfer Pricing Brief: January 2018

February 05, 2018

Hong Kong: CbC reporting requirement-General rule: Inland Revenue (Amendment) (No. 6) Bill 2017 published on 29 December 2017 sets out rules on transfer pricing documentation including country-by-country reporting, and contains other measures to

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Transfer Pricing Brief: December 2017

January 04, 2018

Italy: CbC Reporting requirement-Timing: On December 11, the tax authority issued a Measure no. 288555 extending the due date for filing the CbC report for fiscal year 2016 from 31 December 2017 to 9 February 2018 within 60 days following the

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Transfer Pricing Brief: November 2017

December 05, 2017

Belgium: Main corporate income tax rate: On 27 October 2017, the government has approved the corporate tax reform bill. The rate of corporate income tax will be gradually reduced to 29% in 2018, and will be further reduce to 25% in 2020. Belgium

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