Category: Taxation
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Transfer Pricing Bylaws issued in February 2019 in Saudi Arabia
On 15 February 2019, Saudi Arabia’s General Authority of Zakat and Tax (GAZT, now ZATCA) issued the final Transfer Pricing (TP) Bylaws, marking a significant development in the country’s tax and compliance landscape. These Bylaws were published after a public consultation on a draft version released in December 2018 and were accompanied by a detailed FAQ…
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Business Tax (Country-by-Country Reporting) Regulations, 2021 in Seychelles
Seychelles has implemented Country-by-Country (CbC) Reporting regulations in line with the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13 framework, which aims to enhance tax transparency among large multinational enterprises (MNEs). Key Features of the Regulations Applicability: The regulations apply to MNE groups with consolidated group revenue of at least EUR 750 million and where…
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DIAN Resolution No. 000071 of 2019 in Colombia
DIAN Resolution No. 000071 of 2019 in Colombia prescribes the format for the Fiscal Reconciliation Report (Reporte de Conciliación Fiscal) as required by numeral 2 of article 1.7.1 of Decree 1625 of October 11, 2016. This resolution applies to the tax period 2020 and modifies article 1 of Resolution 000052 of October 30, 2018, which…
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Decree 2120 and 2150 of 2017 in Colombia
Decree 2120 of 2017 and Decree 2150 of 2017 are important regulatory instruments issued by the Colombian Ministry of Finance that address different aspects of the country’s tax system. Decree 2120 of 2017 Issued on December 15, 2017, this decree modifies and substitutes several provisions of the existing tax regulatory framework, specifically related to transfer…
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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: Obligation to Prepare Documentation: Taxpayers subject to income and complementary tax must prepare and submit transfer pricing documentation if they meet certain thresholds regarding their…
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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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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: The ultimate parent company (or its substitute)…
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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: Publication: Issued on 20 October 2017 under Government Gazette 41186. Purpose: Requires Multinational Enterprises (MNEs) to submit CbC Reports, Master Files, and Local Files to SARS under section 25 of the Tax Administration Act. Effective Date: Applies to Reporting Fiscal Years starting on or…
