OECD publishes additional guidance on Country-by-Country Reporting (BEPS Action 13)

  • By A&S
  • June 30, 2016
  • News

On June 29, 2016, the OECD published a memorandum titled Guidance on the Implementation of Country-by-Country (CbC) Reporting. As described in the original press release, the OECD/G20 BEPS Project set out 15 key actions to reform the international tax framework and ensure that profits are reported where economic activities…

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OECD Council approves incorporation of BEPS amendments into the Transfer Pricing Guidelines

  • By A&S
  • June 16, 2016
  • News

On May 23 2016, the OECD Council approved the amendments to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“Transfer Pricing Guidelines”), as set out in the BEPS Report on Actions 8-10 “Aligning Transfer Pricing Outcomes with Value Creation” and the 2015 BEPS Report on Action 13…

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Cape Verde enacts ordinance introducing transfer pricing guidelines

  • By A&S
  • January 14, 2016
  • News

Cape Verde has enacted Ordinance No. 75/2015 (Portaria de 31 de dezembro), which introduces transfer pricing guidelines on arm’s length pricing for related parties. The guidelines are incorporated into articles 65 and 66 of the Corporate Income Tax Code (Codigo do Imposto sobre o Rendimento das Pessoas Coletivas, IRPC)…

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Finland requesting comments on proposal revising transfer pricing documentation rules, introducing Country-by-Country reporting

  • By A&S
  • January 12, 2016
  • News

The Finnish Ministry of Finance has release a proposal for public comment, which includes revisions to the transfer pricing documentation rules and the introduction of country-by-country (CbC) reporting. The draft bill generally follows the OECD’s recommendations outlined in Action 13 (Transfer pricing documentation and country-by-country reporting) of the BEPS…

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New transfer pricing documentation rules enacted in the Netherlands, includes Country-by-Country reporting

  • By A&S
  • January 11, 2016
  • News

The Dutch Upper House (Eerste Kamer) has passed legislation (‘2016 Other Tax Measures’, in English) amending the transfer pricing documentation rules to include country-by-country reporting obligations, as well as master file and local file provisions. The rules are effective from January 1, 2016. The legislation introduces new standardized documentation…

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Japan publishes 2016 Tax Reform Plan

  • By A&S
  • December 18, 2015
  • News

On December 16, 2015, the Japanese government publishes the key measures of its 2016 Budget, including: Reduction of corporate income tax rate from 32.11% (2015) to 29.97% (2016) and 29.74% (2018).;Increase of the consumption tax to 10% from April 2017; Introduction of county-by-country (CbC) reporting on the financial year…

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Second part of Finance Bill 2016 introduced in France, includes changes to transfer pricing documentation rules

  • By A&S
  • November 11, 2015
  • News

The Finance Committee of the French National Assembly has introduced the second part of the Finance Bill for 2016. According to the legislative proposals included in the Bill, it would become mandatory for transfer pricing documentation to be filed with the tax administration in connection with the annual tax…

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Changes to transfer pricing documentation rules proposed in Denmark

  • By A&S
  • September 25, 2015
  • News

On September 18, 2015, the Danish Ministry of Taxation released a draft bill proposing amendments to the current Danish transfer pricing documentation regime. The draft bill sets out to implement the outcomes from OECD BEPS Action 13, i.e. the three-tiered approach to transfer pricing documentation, including country-by-country (CbC) reporting….

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