Canada: General rule for CbC reporting requirement: The Canada Revenue Agency (CRA) updated RC4651 Guidance on Country-By-Country (CbC) Reporting on 2 March 2017 to provide information on the interpretation of Canadian CbC reporting legislation in details.
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Australia: Local file information: As per the guidance published by the ATO, the taxpayer is required to provide copies of International Related-Party Agreements (IRPA) in Part B of the local file for all transactions shown in Part A of the file, unless the transaction is covered by one of the eight categories on the Exclusions List.
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Sweden: BEPS related compliance
Master file information: Sweden has introduced a requirement for a master file in line with the OECD’s base erosion and profit shifting (BEPS) Action 13 final report where information regarding the multinational group is to be provided. The Master file must be prepared by the time when the tax return of the parent company is due.
Local file information: Sweden has introduced a requirement for a local file in line with the OECD’s base erosion and profit shifting (BEPS) Action 13 final report. The local file reporting obligations will be applicable to MNEs that have more than 250 employees and minimum consolidated revenue of SEK 450 million or having a minimum consolidated balance sheet total of SEK 400 million in FY 2017. The content of the local file is consistent with OECD BEPS Action 13 recommendations and is effective from 1 April 2017.
General rule for CbC reporting requirement: The Swedish Parliament adopted new Transfer Pricing documentation requirements as encouraged by BEPS Action 13 on transfer pricing documentation and CbC reporting. Multinational Enterprises (MNEs) with a minimum consolidated revenue of SEK 7 billion (equivalent to EUR 750 million) in FY 2016 will be required to submit a CbC report with the Swedish Tax Agency within one year from the end of the fiscal year. CbC reporting would concern fiscal years starting on or after 1 January 2016 (i.e., retroactively for 2016) and is effective from 1 April 2017. The Country-by-Country (CbC) report must be submitted by a company resident in Sweden that is the parent company of a corporate group. A parent company is a company that is not a subsidiary of any other company in Sweden. 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 average number of employees in each entity must be reported.
Timing: The CbC report must be submitted within twelve months after the end of the tax year.
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Russia: BEPS related compliance
Master file information: The Russian Finance Ministry presented for public discussion a new version of the draft law on 6 March 2017. As per the new version of the draft law, any taxpayer may be required to present the Master file, whether it belongs to a Russian-based or foreign-based MNE group. A master file should include a description of the group’s business, including key value drivers, a description of the five main products/services, including supply chains for those products/services and geographical markets for those products/services in which the group operates, a description of the main intra-group transactions involving the provision of services, a brief functional analysis of the group and a description of key business restructuring events which occurred during the period reviewed.
Local file information: The new version of the Draft eliminates uncertainty over whether members of an MNE group will be required to prepare a Local file in addition to or in place of the existing transfer pricing documentation requirements. Now a Local file is regarded as the only type of documentation in addition to the CbC report and Master file that members of an MNE group would be required to submit in relation to cross-border controlled transactions. The local file will contain material related-party transactions, the amounts involved and the company’s analysis of the transfer pricing determinations made on those transactions.
General rule for CbC reporting requirement: The Russian Ministry of Finance issued a new version of the draft law on 6 March 2017 regarding the introduction of country-by-country reporting in Russia. The new reporting requirements is in line with the Organization for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) Action 13 Final Report. It will be applicable for the 2017 financial year to international groups whose revenue totals RUB50 billion (approx. US$777 million) or more. Voluntary reporting is possible for financial years prior to 2017.
Penalty for non-compliance of CbC reporting: Failure to submit a CbC report or to submit inaccurate information may be subject to a penalty of RUB100,000 for each of the three types of the reporting. For violations identified in 2017 through 2019, there would be a grace period during which fines should not be imposed.
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Italy:

General rule for CbC reporting requirement: The Italian Ministry of Finance issued a Decree on 8 March 2017 providing detailed information regarding the application of CbC reporting rules. The Decree is in accordance with an EU Directive of 25 May 2016 requiring all EU Member States to implement a CbC reporting obligation in their national legislation in accordance with the recommendations of the OECD BEPS Action 13. According to the Decree, all Italian tax resident entities that are Ultimate Parent Entities (UPEs) of an MNE group with annual consolidated group revenue equal to or exceeding €750 million will need to prepare a CbC report. Alternatively, if the UPE is not resident in Italy, and not obligated to file a CbC report in its country of residence, or although obligated to file CbC report there is no exchange of information instrument in place with Italy or there is a systemic failure of the jurisdiction of tax residence of the UPE, any other entity of the group that is resident in Italy would have to prepare the CbC report.
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UK: Main corporate tax rate: The corporate income tax rate in the UK has been reduced to 19% compared to the current 20% rate starting from 1st April 2017.
Restriction on interest deduction: The government introduced the new hybrid mismatch regime legislation in Finance Bill 2017 as per BEPS action 2 and will be effective from January 1, 2017.
Special rules for hybrid instruments or entities: The government introduced rules in Finance Bill 2017 to implement the OECD’s Action 4 Final Report that limit the tax deductions up to £2m of net interest expense per annum that companies can claim for their interest expenses. This was effective from 1st April 2017.
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