Taiwan: Main corporate income tax rate: On 1 September 2017, Taiwan’s Ministry of Finance released tax reform proposals including to increase the corporate income tax (CIT) rate from 17% to 20%. The Proposal will become effective for taxable years beginning on or after 1 January 2018.
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Luxembourg: Adjustments-MAP: Circular No.60 released on 28 August 2017 set out the procedures for the implementation of the mutual agreement procedure (MAP) provided for in bilateral tax treaties as concluded by Luxembourg. The MAP applies to transfer pricing cases and all other cases concerning imposition of tax that are not in line with a tax treaty.
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U.S.: Competent authority arrangement (CAA) with UK: The competent authority arrangement (CAA) for exchange of country-by-country report has been concluded between U.S. and UK on 16 August 2017. The Competent Authorities intend to exchange the CbC Reports automatically through a common schema in Extensible Markup Language (XML).
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Main corporate income tax rate: On 27 September 2017, the US government released a unified tax reform framework proposal including reduction of corporate tax rate to 20%.
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Spain: Specific TP compliance-Form: On 30 August 2017, a new Form 232 is published through a Gazette Order that updates certain existing reporting obligations in connection to related-party transactions and transactions involving parties located in countries or territories identified as “tax havens”. Form 232 must be used for tax periods beginning as of 1 January 2016 available in electronic format.
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Ireland: Documentation-Thresholds: On 12 September 2017, the government announced a report providing recommendations including an option to apply transfer pricing provisions to all corporate taxpayers, irrespective of size. The report will be launched on Budget Day, 10 October 2017 for public consultation.
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Hungary: BEPS related compliance-Master file & Local file: Hungary is expected to introduce rules regarding master file and local file requirements from 2018. The Hungarian government has finalized the draft legislation concerning amended transfer pricing documentation requirements which will be presented to the parliament in the autumn of 2017.
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Mozambique: Requirements-Rule: Mozambique Council of Ministers has approved the regulations on transfer pricing on 12 September 2017. The procedure for the assessment of the transfer pricing transactions between related parties has been introduced in this regulation. The regulations have not been published but are expected to enter into force during January 2018.
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Lithuania: CbC reporting requirement-General rule: On 31 May 2017, the Lithuanian Tax Administrator has approved (Order No VA–47) the reporting rules for the multinational enterprise also known as country by country (CbC) reporting rules. Under this rules, the parent company of the MNE group is obliged to submit a CbC report if consolidated revenues of the MNE group exceed 750 million euros per year. In certain cases, parent company of the MNE group can pass on an obligation to submit a CbC report to another company of MNE group (surrogate parent company).
CbC reporting requirement-Timing: On 31 May 2017, the Lithuanian Tax Administrator has approved (Order No VA–47) the reporting rules for the multinational enterprise also known as country by country (CbC) reporting rules. The CbC report must be submitted within 12 months after the end of MNE’s financial year.
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Turkey: Corporate tax rates: On 27 September 2017, the proposal of increase the corporate tax rate from 20% 22% has been submitted to the parliament under a draft law. The changes are expected to enter into force by 2018.
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Argentina: CbC reporting requirement-General rule: According to Resolution 4130-E published on 20 September 2017, ultimate parent entities of multinational enterprise (MNE) groups that are residents of Argentina with consolidated group revenue of €750 million and above will need to comply with the CbCR requirements for financial years starting on or after 1 January 2017.
CbC reporting requirement-Timing: The CbC report must be submitted by the last business day of the 12 month after fiscal year end. The taxpayer must notify the identity of the reporting entity. This notification must be submitted by the last business day of the 3rd month after fiscal year end.
BEPS related compliance-Penalty for non-compliance: Failure to comply with the CbC reporting rules would be subject to a penalty of AR$ 45,000.
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Uruguay: Information exchange-Multilateral: On 25 September 2017, the Tax Authority issued Resolution No. 6.396/017 providing instructions to financial institutions for reporting information under the Common Reporting Standard (CRS) guided by OECD.
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Netherlands: CbC reporting requirement-General rule: Under the draft tax plan for 2018 presented to Parliament on 19 September 2017, a provision is included allowing the voluntary filing of a country-by-country (CbC) report by the ultimate parent entity located in a country that has not implemented CbC reporting for financial years starting on or after January 1, 2016.
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Switzerland: Information exchange-Multilateral: On 29 September 2017, Swiss Federal Council adopted an ordinance on the international automatic exchange of country-by-country reports on multinational firms. The exchange of country-by-country reports between Switzerland and its partner states would take place from 2020.
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Malaysia: Sample notification letters for CbC reporting: The Inland Revenue Board of Malaysia (IBRM) has recently published two different sample notification letters for entities subject to the country-by-country (CbC) reporting notification requirement.
Two separate sample notifications letters have been issued, one for reporting entities (ultimate holding companies or surrogate holding companies that are tax resident in Malaysia) and the other for non-reporting entities.
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Nicaragua: Requirements-Rule: The transfer pricing rules are in effect as of 30 June 2017 which was enacted by the Nicaraguan Congress through Law No. 822 of 2012.
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Japan: Adjustments-MAP: Recently, the National Tax Agency of Japan has released a guidance on mutual agreement procedures (MAP) on their website. As per the guidance, the NTA has also published the list of countries with which it has a treaty that contains a provision for MAP, as at September 1, 2017. In total, Japan has 63 tax treaties containing a MAP clause, covering 74 jurisdictions.
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