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Article 260-5 of the Colombian Tax Code
Article 260-5 of the Colombian Tax Code establishes the requirements for transfer pricing documentation for taxpayers engaged in transactions with related parties. The key points of Article 260-5 are as follows: Country by Country Reporting Article 260-5 of the Colombian Tax Code is directly related to the country-by-country reporting (CbCR) requirements as part of Colombia’s…
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Country-by-Country Reporting (CbCR) in Colombia
Colombia has implemented the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13 recommendations through its domestic legislation, including Country-by-Country Reporting (CbCR). The Colombian Tax Authority (DIAN) oversees these obligations to enhance tax transparency and combat tax avoidance by multinational enterprise (MNE) groups. This guide provides a comprehensive overview of CbCR requirements in Colombia for…
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Country-by-Country Reporting (CbCR) in Gibraltar
Gibraltar has adopted the OECD’s BEPS Action 13 requirements, including Country-by-Country Reporting (CbCR), as part of its commitment to global tax transparency and international cooperation. The regime is applicable to multinational enterprise (MNE) groups operating in or through Gibraltar, subject to certain thresholds and conditions. This guide outlines the key regulatory aspects, filing procedures, deadlines,…
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Article 41 G of the Chilean Income Tax Law
Article 41 G of the Chilean Income Tax Law establishes the CFC (Controlled Foreign Corporation) rules in Chile. These rules require Chilean taxpayers-whether individuals or entities domiciled, resident, or incorporated in Chile-who directly or indirectly control foreign entities, to recognize certain types of income earned by those foreign entities as if they had accrued or…
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Country-by-Country Reporting (CbCR) in Chile
Chile has aligned its tax transparency rules with the OECD’s BEPS Action 13 recommendations by implementing Country-by-Country Reporting (CbCR). These requirements are designed to provide tax authorities with a comprehensive view of the global operations and profit allocation of multinational enterprise (MNE) groups. This guide outlines the CbCR obligations in Chile, including eligibility thresholds, filing…
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Ordinance No. 51/2019 in Portugal
Ordinance No. 51/2019 in Portugal refers to a modification of the local finance law, enacted on August 16, 2019, as part of the country’s broader administrative decentralization process. This ordinance specifically created a decentralization financing fund and redefined how municipalities participate in VAT revenues. It was implemented alongside Law No. 50/2018, which transferred various powers…
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Ministerial Order No. 367/2017 of Portugal
Ministerial Order No. 367/2017 of Portugal, published on December 11, 2017, approves the official form and filing instructions for the Country-by-Country Reporting (CbCR) notification obligation, known as “Modelo 54” (Model 54). This form is used by multinational enterprise (MNE) groups to notify the Portuguese tax authorities about the entity responsible for submitting the CbCR, as…
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Article 121-A of the Corporate Income Tax Code in Portugal
Article 121-A of Portugal’s Corporate Income Tax Code establishes the requirements for Country-by-Country Reporting (CbCR) for multinational groups operating in Portugal. This provision aligns with international standards, particularly the OECD’s BEPS Action 13 and relevant EU directives. Who Must File The obligation to submit a CbCR applies to: Content of the CbCR The report must…
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Country-by-Country Reporting (CbCR) in Portugal
Portugal has adopted the OECD’s BEPS Action 13 framework, including Country-by-Country Reporting (CbCR) requirements. These obligations aim to improve tax transparency by requiring multinational enterprise (MNE) groups to disclose detailed information about their global allocation of income, taxes, and economic activity. This guide outlines Portugal’s CbCR requirements, including compliance thresholds, filing procedures, deadlines, and applicable…
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Public Notice 1117 (2017) in South Africa
Public Notice 1117 related to Country-by-Country (CbC) reporting in South Africa was published in 2017. Key details include: Thresholds: The 2017 Public Notice 1117 aligns with OECD BEPS Action 13 requirements.
CbC Reporting
Country-by-Country Reporting requirements, solutions, FAQs and general info.
CbC Reporting 