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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.
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Section 25 of the Tax Administration Act, 2011 in South Africa
Section 25 of the Tax Administration Act, 2011, deals with the submission of tax returns in South Africa. In summary, Section 25 ensures that tax returns are complete, accurate, and submitted in the manner required by SARS, holding the signatory responsible for the contents of the return. Country by Country Reporting Section 25 of South Africa’s Tax Administration…
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Country-by-Country Reporting (CbCR) in South Africa
South Africa has implemented the OECD’s BEPS Action 13 recommendations, including the adoption of Country-by-Country Reporting (CbCR) requirements. These obligations form part of the country’s broader strategy to enhance tax transparency and ensure that multinational enterprise (MNE) groups pay taxes where economic activities and value creation occur. This guide provides an overview of South Africa’s…
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Article 11-2 of the Law for Coordination of International Tax Affairs (LCITA) in Korea
Article 11-2 of the Law for Coordination of International Tax Affairs (LCITA) in Korea is a specific provision within the broader framework of the LCITA, which is designed to prevent double taxation and tax avoidance, and to facilitate international cooperation in tax matters. The LCITA is the principal legislative basis for Korea’s transfer pricing, international tax…
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Country-by-Country Reporting (CbCR) in South Korea
South Korea has fully implemented the OECD’s BEPS Action 13 recommendations, including Country-by-Country Reporting (CbCR), through its domestic legislation. The CbCR obligations form a part of the broader transfer pricing documentation requirements and are intended to enhance transparency in the operations of multinational enterprise (MNE) groups. This guide outlines South Korea’s CbCR requirements, including thresholds,…
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Article 134 of the Tax Code of the Republic of Kazakhstan
Article 134 of the Tax Code of the Republic of Kazakhstan regulates the taxation of certain categories of organizations, specifically non-profit organizations and those engaged in activities within the social sphere. It establishes the conditions under which these organizations may be subject to special rules for determining taxable income and the relevant tax reporting requirements.…
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Country-by-Country Reporting (CbCR) in Kazakhstan
Kazakhstan has adopted the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13 recommendations by incorporating Country-by-Country Reporting (CbCR) into its domestic tax legislation. This initiative is aimed at increasing tax transparency and ensuring that profits are reported and taxed where economic activities occur. This guide provides key information for multinational enterprise (MNE) groups with…
CbC Reporting
Country-by-Country Reporting requirements, solutions, FAQs and general info.
CbC Reporting 