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 distribution functions.
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Local file/Master file: On 10 July 2018, the Australian Taxation Office has published Local file instructions 2018 and Local file/master file 2018 guidance in which taxpayers can use them to complete their reporting obligations. The Local file instructions 2018 outlines the basic requirements for the submission of the Local file. The Local file/master file 2018 guidance covers the general criteria for submitting the short form of Local file and the full Local file.
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Peru Master file and CbC Report: On 29 June 2018, the tax administration published the Resolution No. 163-2018/SUNAT in the Official Gazette which outlines the requirements for the submission of the Master file and the CbC report through the SUNAT Virtual internet portal on the SUNAT website.
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New Zealand CbC reporting requirement: On 27 June 2018, taxation (Neutralising Base Erosion and Profit Shifting) act 2018 was received by the Royal assent and entered into force on 1 July 2018. Under the act, a new section is added in the tax administration act to codify the requirement for large multinationals companies in New Zealand to file a Country-by-Country (CbC) report.
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Austria CbC reporting requirement: On 11 July 2018, Federal Council approved two declarations concerning the effective date of the multilateral agreements for the exchange of CbC reports (CbC MCAA) and for the exchange of financial account information (CRS MCAA), which provide for the relevant exchange of information under the mutual assistance convention.
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India CbC reporting requirement: On 27 June 2018, the Central Board of Direct Taxes (CBDT) published an Instruction No. 02/2018 (the Guidance), which sets out guidelines for the proper use of CbC reports. The guideline contains processes and mechanisms of CbC reports to ensure proper reference and compliance in relation to the appropriate use of CbC reports.
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APAs-Bilateral: Recently, the Central Board of Direct Taxes (CBDT) has signed the first ever substantive revision to an India-U.K. bilateral advance pricing agreement (APA) due to certain changes in the way a particular transaction was being carried out.
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Nigeria CbC reporting requirement: On 3rd July 2018, the Federal Inland Revenue Service released guidelines with respect to Country-by-Country (CbC) reporting in Nigeria.
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Canada CbC reporting requirement: On 10 July 2018, the Canada Revenue Agency published a paper announcing the first successful round of CbC reports in Canada. Canada now has automatic access to more information and data that enable the Canada Revenue Agency to better risk assess larger multinational companies with consolidated annual revenues in excess of € 750 million.
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Advance Pricing Arrangement (APA): On July 12, 2018, the Canada Revenue Agency (CRA) issued its Advance Pricing Arrangement (APA) Program Report for the calendar year 2017. In 2017, 36 APAs were completed, most completed over the last 10 years.
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Poland Local file: New transactional materiality thresholds have been introduced for local file under draft law published on 16 July 2018. The thresholds PLN 10 million or EUR 2.5 million approx. will be applied for transactions concerning tangible assets and financing, and PLN 2 million EUR 0.5 million approx. will be applied for other transactions.
Master file: The deadline for filing master file has been extended from 9 to 12 months under the draft law amending transfer pricing regulations published on 16 July 2018. The master file may be prepared in English.
Form: Under the draft law, taxpayers will be required to submit a new electronic form (TP-R form), which will replace the CIT-TP / PIT-TP forms.
Safe Harbour-Rule: Safe Harbour rules have been introduced for two types of transactions, i.e. loans that meet certain requirements and low-value-adding services under the draft law published on 16 July 2018.
Low value-adding services: The optional simplified method for low value-adding services has been introduced under the draft law published on 16 July 2018 , which allows the use of simple 5% mark up without a full analysis – 5% at most for services acquired and 5% at least for services provided.
Restriction on interest deduction: A reduction in the percentage of EBITDA limit under the interest deduction restriction rules from 30% to 20% has been changed under the draft law published on 16 July 2018.
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Mexico Requirements: On 11 July 2018, the Mexican Tax Authority (SAT) updated the country’s existing regulations concerning transfer pricing adjustments as set out in rules 3.9.1.1 to 3.9.1.5 of the Resolución Miscelánea Fiscal. The updates provide that any modification to the prices, amount of consideration, or profit margins of controlled transactions, shall be considered as ‘adjustments.’
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France Master file/ Local File: On 18 July 2018, the French tax authorities published instructions regarding Master / Local file in the context of transfer pricing documentation. As per the guidelines, the new documentation requirements apply for fiscal years beginning on or after 1 January 2018 and correspond to the OECD BEPS action 13.
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Restriction on interest deduction: The arm’s length interest rates used in determining the deductibility of interest payments to shareholders for companies whose fiscal year ends between 30 June 2018 and 29 September 2018 has been recently published by France.
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South Africa MAP: On 25 July 2018, South African Revenue Service (SARS) published a new guide on the mutual agreement procedure (MAP) that allows competent authorities from the governments of contracting jurisdictions to interact with the intent to resolve international tax disputes.
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US CbC reporting requirement: On 25 July 2018, Internal Revenue Service (IRS) updated the information concerning CbC report including jurisdiction status table showing recently signed competent authority arrangements for the exchange of CbC reports; instructions for filing Schedule A (Form 8975) dealing with CbC reporting for multinationals; and clarifications to the Instructions for Schedule A (Form 8975).
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