UK:

BEPS Country-by-Country Reporting Requirement: Clause 122 of the Finance Bill gives the UK Treasury the power to make regulations for implementing the guidance of the OECD on country-by-country reporting. This would be part of the transfer pricing documentation prepared by the parent company of a multinational group and is expected to first apply in 2016.

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Diverted Profit Tax: The Finance Bill 2015 has included the Diverted Profits Tax that will charge multinational groups to UK tax on profits that are artificially diverted away from the UK. The rate of the tax is 25% and was introduced from 1 April 2015.

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Main corporate income tax rate: The main rate of corporation tax is 20% from 1 April 2015 and the tax rate will be charged at a single rate known as the main rate.

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Spain:

BEPS Country-by-Country reporting requirement: The Country-by-Country (CbC) reporting has been introduced by the Spanish Ministry of Finance by a Royal Decree published on March 18, 2015. This new transfer pricing documentation will come into effect in the tax periods starting on and after January 1, 2016.

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US:

BEPS Country-by-Country reporting requirement: The US Treasury Department has announced plans to implement a country-by-country (CbC) reporting requirement starting for fiscal years beginning in 2016 as set out in the guidance issued by the Organization for Economic Cooperation and Development on February 6, 2015.

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Russia:

Financial Services: As per the Draft Law No. 675906-6, the thin capitalization rules will be changed and will be in force from 2016. The controlled debt will be deemed an outstanding debt of a Russian organization in respect of predefined debt obligations.

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Poland:

Financial Services: From 1 January 2015 the “thin capitalization” rules has been extended to include indirect holdings, and the 25 per cent holding rule will be based on voting rights. These rule changes also cover lender and borrower companies which have common direct or indirect shareholders meeting the 25 per cent limit.

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China:

Areas of scrutiny: Tax authority will be looking at the arm’s length nature of outbound payments such as royalties, service fees and management fees as per Public Notice 16 regarding certain corporate income tax matters on outbound payments to overseas related parties.

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Turkey:

Advance Pricing Agreement: The revenue administration in Turkey has published draft guidelines on advance pricing agreement (APA) as information for taxpayers that may be required in applying for an APA. In general, the draft guidelines set forth information that is required or that may be requested by the tax authorities with respect to APA applications.

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