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On December 11, 2017, the Portuguese government issued Order 367/2017 approving the model declaration, “Communication of the Identification of the Declarant Entity – Financial and Tax Declaration by Country” (Model 54), under Article 121-A(4) of the Income Tax Code (ITC). The declaration, which represents a notification for … Read More
On November 28, 2017, Russia published Federal Law No. 340-FZ, implementing the BEPS Action 13 documentation requirements (i.e., CbC reporting, master file, and local file). The measures entered into force on November 27, 2017, will apply from that date, and will be included in Article 105.16 of the … Read More
On December 4, 2017, France announced a transitional measure on CbC reporting. If a parent company located in a jurisdiction that does not have a CbC exchange agreement with France voluntarily submits a CbC report for a financial year beginning on January 1, 2016, and the CbC report is transmitted by … Read More
On November 28, 2017, Italy issued Order 275956 (the “Order”) on country-by-country (CbC) reporting requirements. See BEPS Action 13. The Order implements provisions of the Decree of the Ministry of Economy and Finance of February 23, 2017. With effect from the tax year … Read More
On November 28, 2017, the Belgian tax authorities announced that they would extend the filing deadline to March 31, 2018 for the country-by-country (CbC) report (Form 275 CBC), CbC notification (Form 275 CBC NOT), and the master file (Form 275 MF). These forms were initially due by the … Read More
On November 23, 2017, the OECD issued a press release on the OECD Council approving the contents of the 2017 Update (“2017 Update”) to the OECD Model Tax Convention (the “Convention”) on November 21, 2017. The 2017 Update, which was previously approved by the Committee on Fiscal Affairs on September 28, 2017, will be incorporated … Read More