Category: Country-by-Country (CbyC) Reporting

Inland Revenue (Amendment) (No. 6) Ordinance 2018 gazetted

Hong Kong (HKSAR) – The Inland Revenue (Amendment) (No. 6) Ordinance 2018, which primarily implements the minimum standards of the Base Erosion and Profit Shifting (BEPS) package promulgated by the Organisation for Economic Co-operation and Development (OECD) and codifies the transfer pricing principles into the Inland Revenue Ordinance (Cap. 112)...

More Information… More Intense Transfer Pricing Disputes?

The Central Board of Direct Taxes has recently issued guidance on the appropriate use of the ‘Country-by-Country Report’. The CbC filing was introduced as a result of the OECD/G20 Base Erosion and Profit Shifting project. India also introduced the requirement to file CbC reporting recently with the completion of the...

OECD Releases First CbC Reporting Peer Reviews

The OECD has released the first peer reviews of the country-by-country (CbC) reporting initiative, reporting that practically all countries that serve as headquarters to large multinationals have introduced new transfer pricing documentation requirements to improve transparency. Country-by-country reporting will see tax administrations worldwide collect and share detailed information on all...

Seychelles Needs To Redouble BEPS Efforts: UN Expert

The Seychelles has been told to deploy more resources to implement recommendations from the OECD on base erosion and profit shifting. Ingela Willfors, a United Nations tax expert from the Swedish Ministry of Finance, held discussions on implementation with the Seychelles’ Minister of Finance, Trade, and Economic Planning and in...

Cayman Guides On Compliance With CbC Reporting, FATCA, CRS

The Cayman Islands has released new guidance on the obligation on large multinational groups to file a country-by-country report in the territory and also an update on Common Reporting Standard and US Foreign Account Tax Compliance Act reporting. CbC Reporting Guidance The March 29 guidance from the Cayman Islands’ Department...

Argentina Extends CbC BEPS Reporting Deadline

Argentina’s Federal Administration of Public Income has extended the filing deadline for country-by-country (CbC) notifications. Taxpayers who are part of multinational enterprises now have until May 2, 2018, to file CbC notifications where the ultimate parent company of the multinational group has a December 2017 fiscal year end. The CbC...

India Defers Surrogate Entity CbC Reporting Deadline

The Indian Central Board of Direct Taxes has issued a statement to defer the filing obligation on surrogate parent entities with regards to country-by-country reporting. Section 286 was inserted into the Income Tax Act 1981 through the 2016 Finance Act to introduce a requirement to furnish a country-by-country report. The...

Foreign groups in India have to provide country-by-country report, clarifies govt

All international groups operating in the country will have to provide a country-by-country (CbC) report as per the revised Income tax Act, the government clarified in a finance ministry release issued today. The CbC report is to be furnished by the ultimate parent entity of an international group in the...

Egypt To Receive Tax Information Exchange Support

Egypt is to receive international support to implement new measures in the area of tax transparency and information exchange. Unveiled at a meeting on international tax reform in Cairo on March 7, the OECD and Egypt agreed a new project entitled “Enhancing Domestic Resource Mobilization in Egypt through a better...

Mauritius Finalizes CbC Reporting Regulations

Mauritius last month released the Income Tax (Country-by-Country Reporting) Regulations 2018, setting out the jurisdiction’s rules concerning the filing by multinational groups of transfer pricing documentation. The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under BEPS Action 13. Under the framework,...

Hong Kong Launches CbC Reporting Portal

Hong Kong’s Inland Revenue Department on March 5 launched its new Country-by-Country Reporting Portal. Groups can now register to file CbC reports for accounting periods beginning between January 1, 2016, and December 31, 2017, using the online portal. The CbC report is one element of a new three-tiered standardized approach...

Vizor Software Launches CbC Reporting Solution for Tax Authorities

Tax Authorities in jurisdictions who have joined the OECD/G20’s Base Erosion and Profit Shifting (BEPS) inclusive framework can now avail of Vizor’s new Country-by-Country (CbC) Reporting module to fully meet their obligations set out under Action 13. DUBLIN (PRWEB) FEBRUARY 11, 2018 Today, Vizor Software announced the launch of its...

Cayman Islands Country-By-Country Reporting Regulations Issued

As part of the Cayman Islands’ ongoing commitment to international tax transparency, the Tax Information Authority (International Tax Compliance) (Country-By-Country Reporting) Regulations, 2017 (the “CBCR Regulations“) were issued on 15 December 2017. The CBCR Regulations essentially implement in the Cayman Islands the model legislation published pursuant to the OECD’s Base...

Cyprus Extends Deadline For CbC Reporting Entity Notification

The Cypriot tax authority has extended until January 15, 2018, the deadline for multinational corporations to submit their notifications concerning country-by-country reporting for 2017. The deadline had been December 31. In December 2016, Cyprus issued a decree introducing CbC reporting obligations for multinational enterprises with consolidated group revenue of EUR750m...

South Africa, Belgium, Jersey Extend CbC Reporting Deadlines

South Africa, Jersey, and Belgium are among a handful of territories that have recently announced an extension to the due date for country-by-country reports under the new frameworks being introduced under Action 13 of the OECD’s base erosion and profit shifting Action Plan. The CbC report is one element of...

OECD Issues Further Guidance On CbC Reporting

The OECD has published additional guidance on the implementation of the country-by-country (CbC) reporting requirement proposed under Action 13 of its base erosion and profit shifting (BEPS) project. The guidance, issued on November 30, addresses the following issues: how to report amounts taken from financial statements prepared using fair value...

Bermuda To Exchange MNE Tax Info With The UK

Bermuda and the UK recently signed an agreement providing for the automatic exchange of country-by-country reports. Bermuda is the first UK Overseas Territory to sign a CbC Competent Authority Agreement with the UK, which enables the automatic reporting of corporate income on a country-by-country basis for UK-related transfer pricing enforcement...

Virtual Currency Exchanges and US Customers Beware, IRS is Coming: Expert Blog

In the aftermath of Satoshi Nakamoto’s groundbreaking paper in 2009, money began travelling via a new financial route – virtual currencies. The first Bitcoin exchange was established on February 6, 2010 where Bitcoin traded for the first time for 0.3 cents. Last June, the American Institute of Certified Public Accountants...

Bulgaria Requires CbC Reports By Year End

Bulgaria has said that multinationals covered by the country’s new transfer pricing country-by-country reporting regime should submit their first report by December 31, 2017. Through Order 3LIY-1410, Bulgaria’s National Revenue Agency has newly set out the rules concerning country-by-country documentation, including who the reporting obligations apply to and how to...

Transfer pricing: tighter reporting norms for multinationals notified

CBDT issues final rules for Master File and Country-by-Country reporting NEW DELHI, NOV 1:  The Central Board of Direct Taxes (CBDT) has notified the final rules for maintaining and furnishing of transfer pricing documentation in the Master File and Country-by-Country (CbyC) report. This is largely in line with the draft...

Intercompany Transactions: How does BEPS Change Transfer Pricing?

The OECD’s Anti Base Erosion and Profit Shifting Initiative (BEPS) significantly affects current transfer pricing regimes regarding intangibles, documentation and dispute resolution. Why is Transfer Pricing relevant for BEPS? To avoid base erosion and profit shifting of multinational companies, the OECD initiated an action plan consisting of 15 actions with...

Switzerland agrees to share tax information on multinationals

ZURICH (Reuters) – Switzerland said on Wednesday it would start sharing information on the activities of multinationals in its territory with other countries in 2020, joining an international push to fight tax evasion. The new measures will force about 200 large companies in the low-tax haven to prepare country-by-country reports...

CbCR obligations for Italian entity members of US groups

Concerns have arisen over a temporary misalignment between the US country-by-country reporting regime and Italian legislation. Antonella Della Rovere and Federico Vincenti of Valente Associati GEB Partners explain. An agreement for the automatic exchange of country-by-country reports (CbCR) between Italy and the US (Agreement) came into effect on September 27...

Greek Revenue Services, US IRS Sign Agreement for Tax Data Exchange

The US IRS announced this week on its website that the US has entered into a bilateral competent authority agreement with Greece to exchange country-by-country reports on multinationals. The agreement between the IRS and the Greek Independent Authority for Public Revenue, signed September 27, puts into effect a 2015 deal...

CBDT seeks suggestions on framing of rules on country-by-country reporting

New Delhi [India], Oct.6 (ANI): In keeping with India’s commitment to implement recommendations of 2015 Final Report on Action 13, titled “Transfer Pricing Documentation and Country-by-Country Reporting”, the Department of Income Tax has invited comments from stakeholders and the general public. It has said that these comments and suggestions on...

Public Country-by-Country Reporting; Taxpayers’ Rights

Appropriate Use of Country-by-Country Reports The OECD has now published Guidance (available here) on the appropriate use of Country-by-Country Reports (‘CbCRs’) by national tax authorities. This is in response to some valid MNE concerns that tax authorities may misuse CbCRs. “Appropriate use” is clarified as being for (i) high-level transfer...

Multinationals Fear Japan Reports Could Spur Outside Audits

Japanese multinational companies worry that filing their first country-by-country reports in 2018 will lead to a barrage of transfer pricing audits by developing countries. Companies are currently preparing their first country-by-country reports that must be filed with the National Tax Agency by the end of March 2018. Japan adopted country-by-country...

OECD releases guidance to ensure BEPS country-by-country reports are used appropriately.

Canada has implemented the country-by-country reporting requirement for large multinational enterprises (MNEs) contained in the 2015 Final Report on Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan.  Canada’s legislation is found in s. 233.8 of the Income Tax Act (Canada), and is supported by the...

SARS to crack down on multinational companies and subsidiaries’ tax returns

MEDIUM and large businesses with multinational ties will soon have to start supplying the South African Revenue Service (SARS) with more detailed reports of their relationships and transactions with connected entities residing in other countries. SARS has beefed up its Transfer Pricing Division and is now actively involved in the...

Changes to tax laws in sight for MNCs as the authorities adopt BEPS

MULTINATIONAL corporations (MNCs) in Malaysia will soon be seeing more tax law changes coming their way as the authorities get down to tackling base erosion and profit shifting (BEPS). This follows efforts by the Organisation for Economic Co-operation and Development (OECD), approved by G20 leaders, to formulate a 15-step action...

Germany’s Schaeuble Defends Resistance to EU Public Tax Reporting

German Finance Minister Wolfgang Schaeuble defended his opposition to pending European Union legislation that would force large multinational companies to publicly disclose, on a country-by-country basis, their taxes paid and profits. Schauble, who testified before the EU Parliament’s Panama Papers investigative committee July 11, said public reporting of companies’ tax...

Exchange of information about multinational firms will be easier

Slovakia is the first V4 country to sign the agreement on country-by-country reporting. Slovakia’s Financial Administration has obtained easier access to the information of US multinational companies. The representatives of Slovakia and the US signed a bilateral agreement on country-by-country (CbC) reporting on June 21, the TASR newswire reported. The...

IRS opens Country-by-Country Reporting site online

The Internal Revenue Service has created a new section on its IRS.gov website dedicated to information on the Country-by-Country Reporting rules of the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting project, which aims to discourage tax avoidance by multinational companies. The new Country-by-Country Reporting web pages...

Malta Outlines Last Offer on Public Country-by-Country Reports

European Union-based multinational companies that exceed consolidated revenue of 750 million euros ($840 million) for two consecutive years would have to report publicly on taxes paid, profits earned, and persons employed on a country-by-country basis, under a proposal from Malta. Malta holds the EU presidency, a position it will turn...

Singapore signs two international agreements to facilitate sharing tax info across borders

SINGAPORE – Singapore has signed two international agreements which will make it easier for the country to automatically exchange tax information with other jurisdictions. The agreements are part of ongoing global efforts to combat tax evasion and money laundering as well as improve tax transparency. Called multilateral competent authority agreements...

Tax administrations prepare for automatic exchange of CbC reports – are you ready? Three takeaways

OECD announced that another important step has been taken to implement country-by-country (CbC) reporting requirements, as signatories to the Multilateral Competent Authority Agreement on the Exchange of CbC Reports (the CbC MCAA) activated their automatic exchange relationships. The OECD also signalled that additional jurisdictions will nominate partners with which they...