Category: Country-by-Country (CbyC) Reporting

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… – Continue reading

Hong Kong’s New Transfer Pricing Regime

On December 29, 2017, Hong Kong gazetted the Inland Revenue (Amendment) (No. 6) Bill 2017 (the Amendment Bill). The Amendment Bill, which was formally introduced into the Legislative Council on January 10, represents a crucial step in the development of Hong Kong’s transfer pricing regulatory and enforcement regime. The objectives… – Continue reading

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… – Continue reading

Bermuda Lists CbC Report Exchange Partners

The Bermuda Government on January 31, 2018, updated the lists of the countries with which it will exchange country-by-country reports filed in Bermuda in 2018 and in 2019. The Government has disclosed that it expects to exchange CbC reports with a total of 41 territories in 2018 relating to financial… – Continue reading

Costa Rica Gazettes Country-By-Country Reporting Rules

On February 2, 2018, Costa Rica published Resolution no. DGT-R-001-2018 in its Official Gazette, setting out the rules for filing a country-by-country report. The parent company of a multinational group resident in Costa Rica with consolidated group revenue of the equivalent of EUR750m in the Costa Rican currency – presently… – Continue reading

Sweden Clarifies CbC Reporting Threshold Rules

The Swedish tax authority (Skatteverket), has published guidance on companies’ country-by-country reporting obligations with respect to short and extended tax years, and company divestments and restructurings. Under Sweden’s Tax Procedures Act, a group is not obligated to submit a CbC report if, according to its consolidated accounts, it has a… – Continue reading

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… – Continue reading

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… – Continue reading

Bermuda Premier signs tax agreement with US, visits Jamaica

HAMILTON, Bermuda (CMC) — Bermuda has signed a new tax agreement with the United States that premier David Burt says demonstrates the island’s continued commitment to transparency. Burt, who left here over the weekend for Jamaica, said the Country by Country Competent Authority Agreement signified that the PLP government had… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

Australia Extends CbC Reporting Deadline

The Australian Taxation Office (ATO) has extended until February 15, 2018, the deadline for “significant global entities” to file their country-by-country (CbC) reports. The extension applies to entities that are December and January balancers filing for the first time. The extension also applies to the filing of local and master… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

Oman Joins BEPS Inclusive Framework

Oman has become the latest country to agree to implement the base erosion and profit shifting minimum standards by signing up to the BEPS Inclusive Framework. In implementing the minimum standards, countries agree to remove harmful tax provisions in their domestic tax regimes, amend their tax treaty rules to prevent… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

UK Issues Guidance On Preparing CbC Reports

The UK tax authority, HM Revenue and Customs (HMRC), has issued guidance for businesses on the preparation of country-by-country reports in the required format. The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under Action 13 of the OECD’s base erosion and… – Continue reading

US IRS Now Accepting CbC Reports

The US Internal Revenue Service (IRS) has begun accepting country-by-country (CbC) reports from multinational corporations. In June 2016 the IRS issued final regulations requiring CbC reporting by the ultimate parent entity of a multinational enterprise (MNE) group with revenue of USD850m or more in the preceding accounting year. The first… – Continue reading

Singapore ready to exchange account info with Indonesia

Swop of taxpayer financial data can start when Jakarta puts safeguards in place, says Indranee Singapore stands ready to have a Automatic Exchange of Financial Account Information (AEOI) relationship with Indonesia, as soon as Indonesia is ready, Senior Minister of State for Finance and Law Indranee Rajah has said. This… – Continue reading

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… – Continue reading

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… – Continue reading

IRS opens Country-by-Country Reporting site online

The Internal Revenue Service has created a new section on its 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… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

Russia introduces draft law on country-by-country reporting requirements: implications for multinationals

A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The draft law, published by the Ministry… – Continue reading

OECD’s BEPS 13 implemented in Croatia

With a total of 15 action points, the OECD’s Base Erosion and Profit Shifting (BEPS) project aims at fighting the artificial shift of profits from jurisdictions with high taxes to tax havens, often as a part of an entirely legal strategy used by MNEs. The BEPS Action 13 (Transfer Pricing… – Continue reading

Cyprus: Abolition Of Profit Margins On Intra Group Loans – Upcoming Transfer Pricing Legislation – Transfer Pricing Studies Requirement

As a rule and according to Article 33 of the Cyprus Income Tax Law, which introduces the arm’s length principle (using wording similar to that of article 9 of the OECD Model Tax Convention), all transactions between companies, including loan agreements/transactions by Cyprus companies, must be undertaken at arm’s length… – Continue reading

BEPS from an IP perspective, Part 2

Part 2: Transfer Pricing documentation requirements From 1 April 2017, BEPS action 13 guidelines on transfer pricing (TP) documentation will be effective in Sweden. Action 13 is an effort to make MNEs global financial situation more transparent. It is a three-tiered based approach including a master file, local files and… – Continue reading

Countries ‘losing £400bn in taxes a year to profit shifting’

Governments around the world are losing as much as half a trillion US dollars (£400 billion) a year in tax revenue due to so-called “profit shifting” by multinational companies, according to research. The research published by the Tax Justice Network found that poorer countries were hardest-hit by the practice, which… – Continue reading

Tax executives anticipate Trump reforms

Tax reform is widely expected under the Trump administration by the corporate tax executives polled by BDO USA in a new survey. BDO’s 2017 Tax Outlook Survey polled 100 tax executives at public companies across the U.S., and found that 100 percent of the surveyed tax executives believe tax reform… – Continue reading

Romania Joins BEPS Inclusive Framework

Romania approved legislation to join the OECD’s base erosion and profit shifting Inclusive Framework on March 2. As an Associate member under the Inclusive Framework, Romania will work on an equal footing with other associates and G-20 and OECD countries in the development of further BEPS standards and the peer… – Continue reading

Global transfer pricing standards with local impacts

THE ORGANISATION for Economic Cooperation and Development (OECD) initiated the base erosion and profit shifting (BEPS) project in 2013 to address perceived gaps in international tax rules causing a loss of revenues for governments of about US$100 billion to $240 billion (Bt3.5 trillion to Bt8.4 trillion) annually. The OECD’s BEPS… – Continue reading

Companies Get Draft Instructions for U.S. Global Tax Reports

U.S. multinational companies with more than $850 million in annual consolidated gross income now have draft instructions for filing IRS reports on their global tax and profits. The Internal Revenue Service added instructions to the draft Form 8975 and accompanying draft Schedule A it released in December 2016, companies that… – Continue reading

Irish FM Criticizes EU’s BEPS Response

Irish Finance Minister Michael Noonan has criticized the EU’s proposals for a common consolidated corporate tax base (CCCTB) and public country-by-country (CbC) reporting as “against the BEPS consensus.” In a speech to an event on corporation tax, Noonan said that the consensus over the OECD’s BEPS proposals must hold and… – Continue reading

India: OECD’s Additional Guidance On The Implementation Of Country-By-Country Reporting

A key outcome of the Organisation for Economic Development and Co-operation’s (OECD’s) final Report on Action Plan 13 (Transfer Pricing Documentation and Country-by-Country reporting) is the commitment of OECD and G20 countries to introduce Country-by-Country (CbC) reporting along with the associated master file and local file documentation for large Multinational… – Continue reading

The end of international tax planning?

CROSS-border taxation in current times is poised for significant changes. Tax is key in foreign ventures. Absent tax strategies and foreign tax leakages would erode margins and return of investment. Although international tax-efficient strategies to mitigate capital gains tax (CGT), withholding tax (WHT) and the risk of creating a taxable… – Continue reading

Mauritius joins global efforts to curb profit shifting by MNEs

In a significant step, Mauritius will soon start automatically sharing of tax information with India and other countries as part of global efforts to curb multinational companies from profit shifting activities. The development also comes months after the island nation, long perceived to be a jurisdiction for alleged illegal fund… – Continue reading