Tax & Accounting Blog

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

Brazil Publishes Country-by-Country Reporting Requirements

Brazil Publishes Country-by-Country Reporting Requirements

On December 29, 2016, Brazil published Normative Instruction RFB No. 1681, requiring country-by-country (CbC) reporting. See BEPS Action 13. The ultimate parent entity, or another entity that is a Brazilian tax resident, is required to submit the CbC report. An entity other than the ultimate parent can submit the report if … Read More

Luxembourg Publishes Extended Notifications for Country-by-Country Reporting

Luxembourg Publishes Extended Notifications for Country-by-Country Reporting

On December 27, 2016, Luxembourg published a newsletter, saying that the government has implemented country-by-country (CbC) reporting and the mandatory automatic exchange of CbC information. See BEPS Action 13. On December 13, 2016, the Luxembourg Parliament adopted Law No. 7031, implementing CbC reporting and the mandatory automatic exchange of … Read More

Country-by-Country Reporting Proposals Achieve Royal Assent in Canada

Country-by-Country Reporting Proposals Achieve Royal Assent in Canada

On December 15, 2016, Bill C-29 (“Bill”) received Royal Assent by the Canadian Parliament, implementing certain proposed and confirmed provisions from the March 22, 2016 budget. The Bill includes amendments to the Income Tax Act (“Act”) with respect to CbC reporting (proposed in March 22 budget) and the common reporting standard for the … Read More

Portugal Extends Deadline for Country-by-Country Reporting Notifications

Portugal Extends Deadline for Country-by-Country Reporting Notifications

On December 12, 2016, the Portuguese State Secretary for Fiscal Affairs, Fernando Rocha Andrade, issued Order No.254/2016XXI, extending the deadline for country-by-country (“CbC”) reporting notifications for fiscal year 2016 to May 31, 2017. Under Portugal’s CbC reporting requirements, the group must provide electronically the identity and tax residence of the reporting entity to … Read More

French Constitutional Council Declares Public Country-by-Country Reporting Unconstitutional

French Constitutional Council Declares Public Country-by-Country Reporting Unconstitutional

On December 8, 2016, the French Constitutional Council (“Council”) issued Decision No. 2016-741 DC, which held that specific provisions of Article 137 of the law on transparency, the fight against corruption and the modernization of the economy ("Law No. 830") (i.e., public country-by-country reporting (CbCR)) are unconstitutional. See the corresponding Read More