Tax & Accounting Blog

U.S. IRS Releases Information on Early Filing of Form 8975 and Schedule A

U.S. IRS Releases Information on Early Filing of Form 8975 and Schedule A

On January 19, 2017, the U.S. Internal Revenue Service (IRS) released Revenue Procedure 2017-23, which describes the process for filing Form 8975, Country-by-Country Report, and accompanying Schedule A, Tax Jurisdiction and Constituent Entity Information (collectively, Form 8975), by ultimate parent entities of U.S. multinational enterprise (MNE) groups for reporting … Read More

Indonesia Implements Three-Tiered Transfer Pricing Documentation Requirements

Indonesia Implements Three-Tiered Transfer Pricing Documentation Requirements

On December 30, 2016, the Indonesian Minister of Finance published PMK213/ PMK.03 / 2016, which provides details on the three-tiered transfer pricing documentation requirements (master file, local file and country-by-country (CbC) report) for related party transactions in accordance with BEPS Action 13. The master file must include the following information about … Read More

Ireland Issues FAQs on Qualifying Disclosure for “Offshore Matters”

Ireland Issues FAQs on Qualifying Disclosure for “Offshore Matters”

On January 9, 2017, Ireland issued FAQs on qualifying disclosures relating to offshore matters.  See BEPS Action 12. Ireland has proposed measures in section 54 of the Finance Bill 2016 to address offshore tax evasion in light of the new international measures for exchange of information. If enacted, the proposed legislation … Read More

Austria Publishes Ordinance on Master and Local File Documentation Requirements

Austria Publishes Ordinance on Master and Local File Documentation Requirements

On December 21, 2016, Austria published an Ordinance on transfer pricing documentation in the official gazette, clarifying the requirements for the master and local files, which will apply to years beginning January 1, 2016. See BEPS Action 13. Master File The master file must include the following: Organizational structure of the … Read More

U.S. IRS Updates List of International No-Ruling Areas

U.S. IRS Updates List of International No-Ruling Areas

On January 3, 2017, the U.S. Internal Revenue Service (IRS) issued Revenue Procedure ("Rev. Proc.") 2017-7, superseding Rev. Proc. 2016–7, providing a current list of areas of the Internal Revenue Code (the “Code”), under the jurisdiction of the Associate Chief Counsel (International), on which the IRS will not issue letter rulings … Read More

Chile Publishes Resolution Introducing Country-by-Country Reporting Requirement

Chile Publishes Resolution Introducing Country-by-Country Reporting Requirement

On December 27, 2016, the Chilean tax authorities (Servicio de Impuestos Internos – SII) published Resolution No. 126 (the “Resolution”). The Resolution updates the current annual transfer pricing return (affidavit) requirements to introduce an associated country-by-country (CbC) reporting requirement. See BEPS Action 13. The new CbC requirements include the following: Annual … Read More