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 Shifting (BEPS) Related Compliance:
Master File & Local File Information: Mexico has introduced a requirement for a “master file” and “local file”  file in line with the OECD Base Erosion and Profit Shifting (BEPS) project from 1 January 2016. It will be mandatory to provide information for taxpayers with turnover of above 37.11 billion pesos (about €20 million). Master file will contain information regarding description of the group’s capital structure, transfer pricing policy and significant intangible assets utilized.  A local file will contain specific transfer pricing information for each relevant country of operation. The reporting structure will be in line with the Action 13 of OECD Base Erosion and Profit Shifting (BEPS) project.
General Rule for Country by Country (CbC) Reporting: Mexico has introduced CbC reporting for domestic entities with consolidated turnover above 12 billion pesos that require to provide information concerning the amount of revenue earned and tax paid by location, also activities and places of business for dependent entities and permanent establishments within the group. CbC reporting is applicable to the fiscal year beginning from 1 January 2016. The CbC report must be submitted by a company resident in Mexico that is the parent company of a corporate group. A parent company is a company that is not a subsidiary of any other company whether resident or non-resident in Mexico. The report must cover group revenue, distinguishing between related and unrelated parties; accounting results before corporate income tax (or similar taxes); and corporate tax (or similar taxes) paid or accrued, including withholding tax. The CbC report must be submitted within twelve months after the end of the tax year.
Penalty for Non-Compliance: Non-compliance with the rules would be imposed penalties in a range of MXN 140,540 (USD 8,365) to MXN 200,090 (USD 11,910) and in addition, a failure to file or presenting incomplete or erroneous reports would be penalized by disqualifying the taxpayer from entering into contracts with the Mexican public sector. The Reform will be effective from 1 January 2016.
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Lithuania: Tax Return Filing Due Date: As per the draft amendments to tax laws approved by the parliament of Lithuania on 17 November 2015, the deadline for filing tax returns will be the 15th day of the month following the end of the relevant tax period. It will be effective from 1 January 2016 if adopted by the parliament in final reading.
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Ukraine: Financial Services: Thin capitalization rules included in the draft Law No. 3357 of 26 October 2015.
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Egypt: Main Corporate Tax Rate: As per Law no. 96 of 2015, the income tax rate of the legal entities is 22.5% and which is applicable to the calendar tax year starting from 1 January 2015 to 31 December 2015 or the taxable year ending after 20 August 2015.
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Ghana: Financial Services: As per the Act published in the Official Gazette of Ghana on 1 September 2015, the thin capitalization ratio has been increased to 3:1 from the previous ratio of 2:1.Financial Services: As per the Act published in the Official Gazette of Ghana on 1 September 2015, the thin capitalization ratio has been increased to 3:1 from the previous ratio of 2:1.
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Australia: Base Erosion and Profit Shifting (BEPS) Related Compliance:
Master File & Local File Information: Australia has introduced a requirement for a “master file” and “local file” from 1 January 2016 in line with the OECD Base Erosion and Profit Shifting (BEPS) project. Entities whose annual global revenue exceeds A$1 billion threshold are required to provide a statement to the ATO in relation to an income year. Master file will contain information regarding a statement relating to the global operations and activities, and the pricing policies relevant to transfer pricing.  A local file will contain specific TP information for each relevant country of operation. The reporting structure will be in line with the Action 13 of OECD Base Erosion and Profit Shifting (BEPS) project.
General Rule for Country by Country (CbC) Reporting: Australia has introduced CbC reporting for domestic entities with consolidated turnover above A$1 billion. The CbC report will contain information on the location of the economic activity undertaken by the multinational group including revenue, headcount, main business activities, taxable income and tax paid in each tax jurisdiction globally. The CbC report need to be lodged by the Australian subsidiary of a global group where the group’s parent entity is in a jurisdiction with which Australia has an information sharing agreement in place. CbC reporting is applicable to the fiscal year beginning from 1 January 2016. The CbC report must be submitted by a company resident in Australia that is the parent company of a corporate group. A parent company is a company that is not a subsidiary of any other company whether resident or non-resident in Australia. The CbC report must be submitted within twelve months after the end of the tax year.
Penalty for non-compliance: The maximum penalty for tax avoidance and profit shifting arrangements will be doubled up to a maximum of 120% of the tax avoided for groups with A$1 billion global turnover. The Reform will be effective from 1 January 2016.
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Sri Lanka: Main corporate tax rate: As per the proposed Budget for 2016, the corporate income tax structure will be simplified by imposing two tax rates.  A 30% tax rate will be applicable for banking and finance including insurance, leasing and relating activities; trading activities other than manufacturing or providing services; and betting and gaming; liquor and tobacco. 25% surtax will also be applicable to the income tax liability imposed on the businesses of betting & gaming; liquor and tobacco.  15% tax rate will be applicable for all other sectors including services, manufacturing and agriculture.
Simplified Method: As per the proposed budget for 2016, administration of the transfer pricing on domestic transactions will be simplified.
Penalty for Documentation Failure: As per the proposed budget 2016, penalty provisions will be introduced to ensure proper implementation of transfer pricing regulations.
Penalty in Case of Adjustment: As per the proposed budget 2016, penalty provisions will be introduced to ensure proper implementation of transfer pricing regulations.
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Italy: Base Erosion and Profit Shifting (BEPS) Related Compliance:
General Rule for Country by Country (CbC) Reporting: Italy has incorporated CbC reporting in 2016 approved budget law for domestic entities with a consolidated annual turnover for the year prior to the CbC reporting of at least €750 million. The CbC reporting rules require multinational entities (MNEs) to report, by country, the amounts of gross profit, taxes paid and accrued, and other indicators of effective economic activities. The budget law provisions do not specifically state what is the first year for CbC reporting, but it is expected that CbC reporting would apply to financial year 2016. The CbC report must be submitted by a company resident in Italy that is the parent company of a corporate group. A parent company is a company that is not a subsidiary of any other company whether resident or non-resident in Italy. The CbC report must be submitted within twelve months after the end of the tax year.
Main corporate tax rate: As of FY 2017, the applicable corporate income tax (IRES) rate would be further reduced to 24%.
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Oman: Main Corporate Tax Rate: As per the proposed changes to tax laws approved by the lower house of parliament, the corporate tax rate is expected to be increased from 12% to 15%.
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Korea: Base Erosion and Profit Shifting (BEPS) Related Compliance:
Master File & Local File Information: The Korea’s National Assembly passed the 2016 tax reform bill On 2 December 2015. It requires taxpayers to submit a “Comprehensive Report of Taxpayer’s International Transactions” as “master file” and “local file”  at the time of filing the corporate tax return of the fiscal year commencing on or after 1 January 2016. Master file will contain information regarding a statement relating to the global operations and activities, and the pricing policies relevant to transfer pricing. A local file will contain specific transfer pricing information for each relevant country of operation. The reporting structure will be in line with the Action 13 of OECD Base Erosion and Profit Shifting (BEPS) project.
General Rule for Country by Country (CbC) Reporting: Korea has incorporated CbC reporting for domestic entities with a consolidated annual turnover for the year prior to the CbC reporting of at least €750 million. The CbC reporting rules require multinational entities (MNEs) to report, by country, the amounts of gross profit, taxes paid and accrued, and other indicators of effective economic activities. The amended law will be effective for fiscal years beginning on or after 1 January 2016. The CbC report must be submitted by a company resident in Korea that is the parent company of a corporate group. A parent company is a company that is not a subsidiary of any other company whether resident or non-resident in Korea. The CbC report must be submitted within twelve months after the end of the tax year.
Penalty for non-compliance: Failure to comply with the reporting requirement will result in a noncompliance penalty not exceeding KRW 10million (US$8,500) and will be effective for fiscal years beginning on or after 1 January 2016.
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Japan: Base Erosion and Profit Shifting (BEPS) Related Compliance:
Master File & Local File Information: As per the tax reform outline released on 16 December 2015, Japanese-based multinational companies will require to submit a “Comprehensive Report of Taxpayer’s International Transactions” as “master file” and “local file” at the time of filing the corporate tax return for the fiscal year commencing on or after 1 April 2016. Master file will contain information regarding a statement relating to the global operations and activities, and the pricing policies relevant to transfer pricing. The required information corresponds to the OECD Final Report.  A local file will contain specific transfer pricing information for each relevant country of operation. The reporting structure will be in line with the Action 13 of OECD Base Erosion and Profit Shifting (BEPS) project.
General Rule for Country by Country (CbC) Reporting: A new transfer pricing documentation rule as per OECD BEPS project like Country-by-Country Reporting (CbCR) will be introduced in Japan for the fiscal year commencing on or after 1 April 2016. This new documentation requirement has been introduced in 2016 budget outline.
Main Corporate Tax Rate: As per the tax reform outline released on 16 December 2015, the headline corporate income tax rate will be reduced from 32.11% to 29.97% in 2016 and will further reduce to 29.74% in 2018.
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Denmark: Base Erosion and Profit Shifting (BEPS) Related Compliance:
General Rule for Country by Country (CbC) Reporting: Danish Parliament has approved the bill introducing Country-by-Country (CbC) reporting for domestic entities with consolidated turnover exceeding DKK5.6b (approx. €750m). The CbC reporting rules require multinational entities (MNEs) to report, by country, the amounts of gross profit, taxes paid and accrued, and other indicators of effective economic activities. This CbC reporting is applicable for fiscal years beginning on or after 1 January 2016.  The CbC report must be submitted by a company resident in Denmark that is the parent company of a corporate group. A parent company is a company that is not a subsidiary of any other company whether resident or non-resident in Denmark. The CbC report must be submitted within twelve months after the end of the tax year.
Penalty for non-compliance: The Danish tax authorities may impose a penalty of DKK 250,000 (EUR 35,000) per year, per Danish company if the transfer pricing documentation or CbC reporting does not comply with the legislation.
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France: Base Erosion and Profit Shifting (BEPS) Related Compliance:
General Rule for Country by Country (CbC) Reporting: The French Parliament has approved the bill introducing Country-by-Country (CbC) reporting for domestic entities with consolidated revenue of €750 million or more. The CbC reporting rules require multinational entities (MNEs) to report, by country, the amounts of gross profit, taxes paid and accrued, and other indicators of effective economic activities. This CbC reporting is applicable for fiscal years starting on or after 1 January 2016 and the report will have to be filed online within twelve months from the closing of each fiscal year. The CbC report must be submitted by a company resident in France that is the parent company of a corporate group. A parent company is a company that is not a subsidiary of any other company whether resident or non-resident in France. The CbC report must be submitted within twelve months after the end of the tax year.
Penalty for non-compliance: Penalties for non-filing would be €100,000.
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US: Base Erosion and Profit Shifting (BEPS) Related Compliance:
General Rule for Country by Country (CbC) Reporting: 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 Co-operation and Development (OECD) recommendations for country-by-country reporting. As per the proposed regulations REG-109822-15, All US persons those are the ultimate parent entity of a multinational enterprise (MNE) group with annual revenue of $850 million or more for the immediately preceding annual accounting period would be required to file a CbC Reporting. The CbC reporting rules will apply to taxable years of ultimate parent entities of U.S. MNE groups that begin on or after the date of publication of the Treasury decision adopting these rules as final regulations in the Federal Register.
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Ireland: Base Erosion and Profit Shifting (BEPS) Related Compliance:
General Rule for Country by Country (CbC) Reporting: Ireland has enacted Country-by-Country (CbC) reporting for domestic entities with consolidated revenue of €750 million or more. The CbC reporting rules require multinational entities (MNEs) to report, by country, the amounts of gross profit, taxes paid and accrued, and other indicators of effective economic activities. This CbC reporting is applicable for fiscal years starting on or after 1 January 2016 and the report will have to be filed online within twelve months from the closing of each fiscal year. The CbC report must be submitted by a company resident in Ireland that is the parent company of a corporate group. A parent company is a company that is not a subsidiary of any other company whether resident or non-resident in Ireland. The CbC report must be submitted within twelve months after the end of the tax year.
Penalty for non-compliance: Failure to provide the CbC report or providing an incomplete or inaccurate report will trigger a penalty of €19,045. In some instances, a further penalty of up to € 2535 may be charged for each day during which the default continues.
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