Costa Rica:  Filing of annual transfer pricing return: Costa Rica has published a resolution in the official gazette to finalize the rules concerning the filing of an annual transfer pricing return for taxpayers qualifying as “large taxpayers” or as “national large companies” or operating under a free trade zone regime and having inter-company transactions in Costa Rica. As per the resolution, the due date for filing transfer pricing return is the last business day of June in the year following the tax year. The first transfer pricing return for 2015 and the transfer pricing return for 2016 will both be due on the last business day of June 2017.
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Russia:  BEPS related compliance:
Master file information: As per the new version of the draft law published on 6 September 2016, Master file is obligatory only for Russian parented groups. A master file should include a full list and key terms of all intercompany agreements relative to the controlled transactions and a full functional analysis, whereby the OECD recommendation is to require disclosure of only service agreements and a brief functional analysis.
Local file information: As per the new version of the draft law published on 6 September 2016, Russian group members will be required to submit a local file which will be needed only for transactions with foreign group members qualifying as ”related parties” under Russian transfer pricing law.
General rule for CbC reporting requirement: The Russian Ministry of Finance issued a new version of the draft law on 6 September 2016 regarding the introduction of country-by-country (CbC) 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 for 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: As per the draft law issued on 6 September 2016, failure to submit notifications or to submit inaccurate information may be subject to a penalty of RUB50,000. Failure to submit a CbC report, a master file or a local file 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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France:  Main corporate tax rate: The government of France announced that the current corporate income tax rate of 33.33% will be reduced in the 2017 fiscal Budget.  Starting from 2017, a lower rate of 28% will be applicable to small and medium-sized enterprises (SMEs) for profits up to EUR 75,000 and by 2020, all businesses will be benefited from this lower rate.
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New Zealand Financial services: The government of New Zealand released a consultative discussion document on 6 September 2016 containing proposals for addressing hybrid mismatch arrangements. The document proposes that New Zealand adopts the 2015 OECD recommendations on hybrid mismatch arrangements.
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Brazil Resale price method: Private Ruling 63/2016 published in the Official Gazette of 31 August 2016, clarified that under the transfer pricing resale price method, the fixed profit margins apply according to the economic sector of the legal entity. In the case of resident companies importing, for resale, chemical products listed in chapter 38 of the tax on industrialized products table, the applicable fixed profit margin is 30%.
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China: Transfer pricing requirement: SAT Bulletin No. 42 published on July 13, 2016 has replaced the existing transfer pricing documentation regulations in Circular Guoshuifa [2009] No. 2, known as Circular 2.
Definition of related party: As per Bulletin 42, two parties will be considered related if they have “other substantial common interests.” The regulation recognizes that related-party relationships may change, and relationships should be recognized during the periods when they exist.
Intangibles property: The definition of “intangibles” extends to include commercial secrets, client lists, sales channels, government licenses and other similar items in SAT Bulletin No. 42 published on July 13, 2016.
Intra-group services: SAT Bulletin No. 42 published on July 13, 2016 by China’s State Administration of Taxation (SAT) has introduced an entirely new requirement for the preparation of a Special File wherever a taxpayer engages in intra-group service transactions. The Special File would contain copies of the relevant inter-company agreements, documentation of service cost identification and allocation keys. SAT Bulletin No. 42 also encompasses the provision of services and the recipient, the specific content of services, features, operation method, pricing principles, forms of payment, as well as to benefit the parties after the occurrence of labor and so on.
Documentation requirement for cost contribution arrangements: Cost contribution arrangements: SAT Bulletin No. 42 published on July 13, 2016 has included some special items in documentation requirement for CSA’s.
Special report on debt to equity ratio: A Special Report is required demonstrating that the taxpayer’s related party debt levels are consistent with the arm’s length principle if its debt to equity ratio exceeds specified ratios.
Main corporate tax rate: Circular Cai Shui [2014] no 59 has extended the 15% tax rate to Technologically Advanced Service Enterprises (TASEs) in 21 trial cities until 31 December 2018. These must provide qualifying services and 50% of employees must have an associate degree or above.
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Denmark: General rule for CbC reporting requirement: A Danish executive order No. 1133 dated 27 August 2016 was issued to provide detailed rules on notice requirements and on how the CbC report must be completed. The executive order was effective from 1 September 2016.
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Switzerland: Main corporate tax rate: The Swiss Corporate Tax Reform III (CTR III) foresees gradual reduction of corporate tax rate over a period of five years from the current maximum rate of 20.7% to approximately 14% (including federal tax).
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Netherlands: Definition of related party: As per the tax budget proposal for fiscal year 2017 issued by the Dutch Ministry of Finance, A party is considered a ”related party” – among others – if an entity has at least one third interest in the Dutch party or is (in)directly owned at least one third by an entity that (in)directly owns at least one third interest in the Dutch party.
Tax treatment of interest on related party loans: As per the tax budget proposal for fiscal year 2017 issued by the Dutch Ministry of Finance, the deduction of interest, including related costs and currency exchange results, by a Dutch company on a related-party loan is to be disallowed to the extent that the loan is used to finance capital transactions with related parties, e.g., acquisition of shares, dividend distributions and capital contributions (tainted transactions). The interest deduction related to tainted transactions might however still be allowed if it can be argued that there are predominantly business reasons for the transaction and the debt financing.
Main corporate tax rate: As per the tax budget proposal for fiscal year 2017, it is suggested to expand application of the 20% rate to profits up to €250,000 as of 1 January 2018, to €300,000 as of 1 January 2020 and to €350,000 as of 1 January 2021.
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UK: General rule for CbC reporting requirement: The UK Government has accepted a cross-party backbench amendment to Finance Bill 2016 which gives HM Treasury powers to introduce public country-by-country reporting (CBCR).
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