Sweden: BEPS related compliance
Master File information: The Swedish Tax Agency has submitted a proposal to the Swedish Government for new Transfer Pricing documentation like Master File. Under the current proposal, the Master File reporting obligations will be applicable to Multinational Enterprises (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 Master File will be consistent with OECD BEPS Action 13 recommendations and will be effective from 1 January 2017.
Local File information: The Swedish Tax Agency has submitted a proposal to the Swedish Government for new Transfer Pricing documentation like Local File. Under the current proposal, the Local File reporting obligations will be applicable to Multinational Enterprises (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 will be consistent with OECD BEPS Action 13 recommendations and will be effective from 1 January 2017.
General rule for CbC reporting requirement: The Swedish Tax Agency has submitted a proposal to the Swedish Government for new Transfer Pricing documentation requirements as encouraged by BEPS Action 13 on transfer pricing documentation and Country-by-Country (CbC) reporting. Under the current proposal, multinational enterprises 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).
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India:  Advance Pricing Agreement (APA): The Delhi Bench of the Income-tax Appellate Tribunal held in the case Ranbaxy Laboratories Ltd. v. ACIT (ITA No. 196/Del/2013) that the foreign related parties are to be considered as “tested parties” with due consideration to a prior advance pricing agreement (APA) reached between the taxpayer and the Central Board of Direct Taxes.
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Denmark: Alternative Dispute Resolution (ADR):  The Minister of Taxation announced plans for the introduction of alternative dispute resolution (ADR) to handle the transfer pricing cases in smooth and timely manner.
Documentation requirement: The Minister of Taxation issued order BEK no. 401 and 402 regarding transfer pricing documentation. The new documentation guidelines BEK no. 402 will replace the previous guidelines of BEK no. 42. The guidelines include more specific documentation requirements than under the previous documentation guidelines. The new documentation guidelines will be applicable from 1 January 2017.
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Australia: Penalty in case of adjustments: The Australian Taxation Office (ATO) released Practice Statement Law Administration 2016/2 (PS LA 2016/2) to deal with the application of transfer pricing penalties during the transition period between 1 July 2004 and 28 June 2013. PS LA 2016/2 also explains the calculation of the shortfall penalties and matters that are relevant for a partial reduction of the penalties.
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Peru: Modification and replacement of the electronic form: The tax authority (SUNAT) in Peru on 30 April 2016 published two new transfer pricing-related forms (Form No. 3530 & Form No. 3560). Form No. 3560 modifies and replaces the prior version of the electronic form No 1630. These new forms are to be used by taxpayers in making their transfer pricing declarations beginning after 1 May 2016.
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Austria: BEPS related compliance
General rule for CbC reporting requirement: Austria has proposed draft legislation to introduce the Country-by-Country (CbC) reporting  rules pursuant to the OECD’s three-tier transfer pricing documentation approach for the fiscal years starting on or after 1 January 2016. Multinational Enterprises (MNEs) or a local subsidiary with a global consolidated group turnover exceeding €750 million in the previous year would be required to submit country-by country (CbC) reports containing the information in Annex III of the OECD’s BEPS Action 13 final recommendations.
Master File information: Austria has proposed draft legislation to implement the Master File in line with the new OECD standard. All entities belonging to a multinational enterprise group that are tax resident in Austria would have to prepare a Master File. The Master File would provide comprehensive information of the multinational enterprise group. Austrian entity would be exempt from the Master File documentation requirement if it has a turnover equal to or below €50 million or intragroup sales commission equal to or below €5 million.
Local File information: Austria has proposed draft legislation to introduce Local File requirement as per the recommendations of the OECD’s base erosion and profit shifting (BEPS) Action 13. A local file will contain specific transfer pricing information for each relevant country of operation.
Penalty for non-compliance: The draft legislation of Austria has proposed a maximum penalty of €80,000 if the CbC reporting requirements are not met. The Austrian draft legislation does not include any penalties for the Master File and the Local File.
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Norway: BEPS related compliance
General rule for CbC reporting requirement: The Norwegian Government has sent its draft bill on the domestic Country-by-Country (CbC) reporting rules to the Norwegian tax authorities. As per the proposal, all multinational groups with annual consolidated group revenue equal to or exceeding NOK6.5 billion (approximately US$730 million) will be obliged to file a CbC report. The CbC report shall be submitted in the jurisdiction where the group’s ultimate parent company is tax resident and shall be exchanged with the jurisdictions where the group operates (i.e., through a subsidiary or permanent establishment) by using exchange of information agreements. If enacted, the CbC reports will be submitted by 31 December 2017 for the fiscal year beginning 1 January 2016 or later.
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Belgium:  BEPS related compliance
General rule for CbC reporting requirement: Belgium has proposed draft legislation to introduce the Country-by-Country (CbC) reporting rules pursuant to the OECD & EU documentation provisions. It would be effective from assessment year 2017. Qualifying groups with a consolidated gross turnover exceeding €750 million would have to file the CbC report with the Belgian tax authorities within 12 months after the closing of the consolidated financial statements of the group.
Master File information: Belgium has proposed draft legislation to implement the Master File in line with the new OECD & UN standard. All entities belonging to a Multinational Enterprise (MNE) group that are tax resident in Belgium would have to prepare a Master File. The Master File would provide comprehensive information of the MNE group. The Master file would have to be filed with the Belgian tax authorities within a period of 12 months after the close of the reporting period of the group.
Local File information: Belgium has proposed draft legislation to introduce local file requirement as per the recommendations of the OECD’s base erosion and profit shifting (BEPS) Action 13. A local file will contain specific transfer pricing information for each relevant country of operation.
Penalty for non-compliance: The draft legislation of Belgium has proposed penalties ranging from €1,250 to €25,000 if the CbC reporting requirements are not met.
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Sri Lanka: Main corporate income tax rate: As per the proposed revised Budget for 2016, a 28% tax rate will be applicable for banking and finance business including insurance, leasing and trading activities other than manufacturing or providing services. The tax rate for betting and gaming; liquor and tobacco business will be 40%. Tax rate of 17.5% will be applicable for all other sectors including services, manufacturing and agriculture.
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South Africa: Incorporation of details transfer pricing sections in tax returns: The South African Revenue Service (SARS) introduced certain changes for incorporating transfer pricing sections in details to the Income Tax Return for Companies (ITR14).
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