Category: CbC
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Section 233.8 of the Income Tax Act (Canada)
Section 233.8 of the Income Tax Act in Canada pertains to Country-by-Country (CbC) reporting requirements for multinational enterprise (MNE) groups. Here are the key aspects of this section: Definitions The section begins by defining important terms: Reporting Obligations The reporting requirements under this section apply to: Purpose and Use of CbC Reports The CbC reports…
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Country-by-Country Reporting (CbCR) Regulation in Canada
Canada’s Country-by-Country Reporting (CbCR) requirements are aligned with the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13 framework. The legislation, overseen by the Canada Revenue Agency (CRA), mandates multinational enterprises (MNEs) with significant operations in Canada to provide transparent financial information. This guide details the requirements and implications of Canada’s CbCR rules, including applicability,…
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Country-by-Country Regulation in Belgium
Belgium has implemented the Country-by-Country Reporting (CbCR) requirements in line with the OECD’s BEPS Action Plan, specifically following Action 13 on transfer pricing documentation. The regulation is enforced by the Belgian Federal Public Service (FPS) Finance, which oversees MNE compliance with CbCR obligations. This guide provides finance directors of multinational enterprises (MNEs) operating in Belgium…
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SAT Bulletin [42/2016] (China)
SAT Bulletin [2016] No. 42, issued by China’s State Administration of Taxation (SAT) on June 29, 2016, introduced significant changes to China’s transfer pricing compliance requirements. Here are the key aspects of this bulletin: New Documentation Framework Bulletin 42 established a three-tiered documentation structure, aligning with the OECD’s BEPS Action 13 recommendations: This replaced the…
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What is ADE COCAD No. 9/2017 (Brazil)
ADE COCAD No. 9/2017 is an important regulation in Brazil related to the disclosure of beneficial ownership information. Here are the key points about this regulation: Purpose and Scope ADE COCAD No. 9/2017 (Executive Declaratory Act – Registration Management General Coordination) was published on October 23, 2017, in Brazil’s Official Gazette. It establishes rules for…
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What is Normative Instruction (IN) No. 1,681 (Brazil)
Normative Instruction (IN) No. 1,681, issued on December 28, 2016 by the Brazilian Federal Revenue Service, established the rules for Country-by-Country (CbC) reporting in Brazil. This instruction implemented Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) Project, which aims to enhance transparency in international taxation. Key Aspects of IN 1,681/2016 Reporting Obligation…
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Country-by-Country Reporting (CbCR) Regulation in the Canary Islands
The Canary Islands, an autonomous community of Spain with a unique fiscal regime, are subject to Spain’s national laws on tax matters while benefiting from specific incentives as part of their Economic and Fiscal Regime (REF). However, when it comes to international tax compliance, including Country-by-Country Reporting (CbCR), multinational enterprises (MNEs) operating in or through…
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Country-by-Country Reporting (CbCR) Regulation in Navarra
Navarra, an autonomous region in Spain with its own fiscal autonomy, implements international tax regulations in line with the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Action Plan, specifically Action 13, which focuses on Country-by-Country Reporting (CbCR). The CbCR regime requires large multinational enterprise (MNE) groups to disclose detailed…
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Country-by-Country Reporting (CbCR) Regulation in Araba
Araba, one of the three provinces in the Basque Country in Spain, has its own fiscal system, which operates under the local autonomy granted by Spanish law, while also adhering to international tax transparency standards such as the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13. This regulation includes the Country-by-Country Reporting (CbCR) regime,…
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Country-by-Country Reporting (CbCR) Regulation in Gipuzkoa
Gipuzkoa, part of the Basque Country in Spain, operates its own independent tax system while adhering to international tax transparency standards, including those outlined by the OECD in BEPS (Base Erosion and Profit Shifting) Action 13. Country-by-Country Reporting (CbCR) is one of the key tools used to ensure that multinational enterprises (MNEs) report their income,…
CbC Reporting 