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Transfer Pricing Documentation Master File, Local File, and CbCR |Actions 13 BEPS Final Reports|
Selected Countries implementation BEPS Action 13 PMK 213/2016
|Passion for Excellence|
2
What is Base Erosion and Profit Shifting (BEPS)? Tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity. Some of the schemes used are illegal, most are not. Undermines the fairness and integrity of tax systems only MNES can use BEPS to gain a competitive advantage over enterprises that operate at a domestic level.
Undermines voluntary compliance by all taxpayers.
|Passion for Excellence|
3
15 BEPS Actions Plans Action 2: Neutralising the Effects of Hybrid Mismatch Arrangements
Action 3: Designing Effective CFC regulations
Action 4: Limiting Base Erosion Involving Interest Deductions and Other Financial Payments
Action 5: Countering Harmful Tax Practices
Action 12: Mandatory Disclosure Rules
Action 11: Measuring and Monitoring BEPS
Actions 8-10: Aligning Transfer Pricing Outcomes with Value Creation
Action 7: Preventing the Artificial Avoidance PE
Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances
Action 13: Transfer Pricing Documentation and Country-by-Country Reporting
Action 14: Dispute Resolution Mechanisms
Action 15: Developing a Multilateral Instrument
Action 1: Addressing the Tax Challenges of the Digital Economy
|Passion for Excellence|
4
A three-tiered approach to TPD Country-byCountry Report (CbCR) Local File • Detailed intercompany transactions. • ALP Price testing
• Global allocation income, taxes, economic activities • NO ALP Price testing
Master File • “Blueprint” of the MNE group TP Policies • NO ALP Price testing
Split of information based on audiences
|Passion for Excellence|
5
Local File
WHAT • detailed information relating to specific intercompany transactions. PURPOSE • supplements the master file and assures taxpayer has complied with the ALP SCOPE • information relevant to the transfer pricing analysis related to TP transaction
|Passion for Excellence|
6
Local File No Subject 1 Identity and Business Activity
Description •
management structure
•
Business and business strategy
•
Operational aspects for Taxpayer’s business activity
•
overview of business environment
•
Transaction scheme and the explanation
•
Pricing policy applied in the last 5 (five) years
•
Explanation over each transactions
•
The transaction amount specified per transaction type and per counterparty
•
Details transactions for commodity products
•
Copy of the agreement
3 The application of the arm’s length principle •
comparability analysis
2 Information on Affiliated Transaction and independent transaction conducted by the Taxpayer
•
business characterization
•
Transfer Price Determinaion method
•
Tested party and PLI
•
summary of the assumptions used in the Transfer Pricing method
•
Comparables and TP Methods implemented
•
TP Analysis
•
copy of the Advance Pricing Agreement (APA) |Passion for Excellence|
7
Local File No
Subject
4 The Taxpayer’s Financial Information
5 Non-financial /facts affects the pricing or the profit level
Description •
Financial Statement
•
Segmented FS
•
the usage of informations in the financial report to the TP Methods
•
relevant financial informations from the comparables
•
-
|Passion for Excellence|
8
Master File WHAT • Overview of the MNE group business (Operations, TP Policies, Global allocation income and economic activity)
PURPOSE: • Evaluating the presence of significant transfer pricing risk • Providing with a high-level overview of the MNE’s global operations and policies. LEVEL OF DETAILS: • Important information should be presented. Important? if its omission would affect the reliability of the transfer pricing outcomes.
SCOPE: WHOLE VS LINE OF BUSINESS • Whole MNE, however, line of business is permitted (justification: e.g. where some significant business lines operate largely independently or are recently acquired). • BUT, the entire master file of all business lines should be available to each country. |Passion for Excellence|
9
Master File
5 level Information No
Subject
1 Organisational structure 2 Description of MNE’s business(es)
Description • Chart illustrating the MNE’s legal and ownership structure and geographical location of operating entities. • Important drivers of business profit; • Supply chain for the group’s five largest products and/ or service offerings by turnover plus any other products and/or services amounting to more than 5 percent of group turnover
• Important service arrangements between members of the MNE group, other than research and development (R&D) services, • A description of the main geographic markets for the group’s products and services that are referred to in the second bullet point above; • Functional analysis describing the principal contributions to value creation by individual entities within the group • Important business restructuring transactions, acquisitions and divestitures occurring during the fiscal year.
|Passion for Excellence|
10
Master File No Subject 3 MNE’s intangibles
Description • •
4 Financial activity and financing • in the Business Group • • • 5 The Consolidated Financial • Report of The Parent Entity and the taxation information in relation to Affiliated • transaction
MNE’s overall strategy for the DEMPE location of principal R&D, facilities and location of R&D management.
Explanation about financing conducted by the Business Group explanation about members of the Business Group carrying financial/financing center to the members, the country/jurisdiction where the Business Group members established and the effective management located Financing agreement between Business Group members Consolidated Financial Statement of the Business Group for the concerned Taxable Year (for external or internal interest)
Advance Pricing Agreement (APA) owns by members of the Business Group and other tax provisions
|Passion for Excellence|
11
CbCR WHAT • Aggregate tax jurisdiction-wide information of global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which the MNE group operates. • A listing of all the Constituent Entities for which financial information is reported PURPOSE
• High-level transfer pricing risk assessment purposes. • It may also be used by tax administrations in evaluating other BEPS related risks • Economic and statistical analysis.
|Passion for Excellence|
12
CbCR IMPORTANT NOTE • NOT a substitute for a detailed TP analysis of individual transactions • NOT conclusive evidence that appropriateness of TP • NOT to propose TP adjustments based on a global formulary apportionment of income.
|Passion for Excellence|
13
CbCR Overview of allocation of income, taxes and business activities by tax jurisdiction
|Passion for Excellence|
14
CbCR List of all the Constituent Entities of the MNE group included in each aggregation per tax jurisdiction
|Passion for Excellence|
15
Objectives of TPD
1.Taxpayer’s assessment of its compliance with the arm’s length principle
transfer pricing risk assessment
1.Enabling thorough TP audit 2.
Par. 5 of BEPS Report Action 13
|Passion for Excellence|
16
transfer pricing risk assessment
Contemporaneous documentation
WHAT? Documentation and information that taxpayers have relied upon to determine the TP 1. prior to or at the time of undertaking the transactions, or 2. in any event, no later than the time of completing and filing the tax return for the fiscal year in which the transaction takes place (Ex-Ante approach)
WHY? 1. Ensuring a culture of compliance. 2. Ensuring the integrity of the taxpayers’ positions and restrain taxpayers from developing justifications for their positions after the fact.
ISSUES 1. costs, time constraints, and competing demands for the attention of relevant personnel 2. Retroactive Adjusment |Passion for Excellence|
17
Ex-Ante vs Ex-Post Approach Fiscal Year Ex-ante: Price Setting Approach Forward Looking Presentation • Information available at the time when the intercompany transaction take place (ex: Comparable transactions from previous years, budget figures based on economic and market changes between the previous and tested year.) • Regular monitoring process between budget and actual figures required • No retroactive adjustments
• Documentation on the price setting process itself
Ex-post: Outcome Testing Approach Retroactive Adjustment • Information available at the time before closing of the books or before the tax return is filed (ex: Actual figures on revenues and cost structure) • Retroactive adjustments in order to achieve an arm’s length outcome • Documentation often based on database studies
|Passion for Excellence|
18
Compliance Issues
Materiality
• local file purposes, based on local conditions
Retention of documents
• Reasonable and consistent with domestic law
Frequency of documentation updates
• Annual update and review
Language
• Based on local law and commonly used language
|Passion for Excellence|
Penalties
• failure or nottimely submission: civil or administrative monetary penalties
Confidentiality
• No public disclosure
Other
• Local comparable is preferred, if available.
19
Implementation CbCR
Master file & Local File • Implemented through local country legislation
Timing: Beginning on or after 1 January 2016 Target:MNE groups with annual consolidated group revenue: preceding fiscal year of more than EUR 750 million or a equivalent amount in domestic currency as of January 2015 Principle: consistent, confidential, and proper use Automatic Exchange of Information Implementation package for government-to-government exchange of Country-by-Country Reports (Annex IV to Chapter V)
|Passion for Excellence|
20
World’s Income Tax Rates in 2016 |Below 25% (1/2) No 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
LOCATION Bahamas Bahrain Bermuda Bonaire, Saint Eustatius and Saba Cayman Islands Guernsey Isle of Man Vanuatu Montenegro Bosnia and Herzegovina Bulgaria Gibraltar Macedonia Paraguay Qatar Macau Moldova Oman Cyprus
% 0 0 0 0 0 0 0 0 9 10 10 10 10 10 10 12 12 12 12.5
|Passion for Excellence|
No 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39
LOCATION Ireland Liechtenstein Albania Georgia Iraq Kuwait Latvia Lebanon Lithuania Mauritius Serbia Sri Lanka Romania Hong Kong Singapore Slovenia Taiwan Switzerland Belarus Ukraine
% 12.5 12.5 15 15 15 15 15 15 15 15 15 15 16 16.5 17 17 17 17.92 18 18
World’s Income Tax Rates in 2016 |Below 25% (2/2) No
LOCATION
40
Czech Republic
41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58
Hungary Poland
Afghanistan Armenia Cambodia Croatia Estonia Fiji Finland Iceland Jersey Jordan Kazakhstan Libya Russia Saudi Arabia Thailand Turkey
No
LOCATION
19
59
United Kingdom
20
19 19 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20
60 61 62 63 64 65 66 67 68 69 70 71 72 73
Yemen Portugal Botswana Curacao Denmark Ecuador Slovakia Sweden Syria Vietnam Egypt Chile Malaysia Korea, Republic of
20 21 22 22 22 22 22 22 22 22 22.5 24 24 24.2
%
|Passion for Excellence|
%
22
CbC reporting frameworks (1/3)
Jurisdiction
Primary law in place
First fiscal year covered for Secondary law filing by in place Ultimate Parent Entity January 1, 2017
Argentina
-
Australia
X
X
Austria
X
Not required
Belgium
X
Brazil
X
Bulgaria Canada
Local Filing required?
First fiscal period for which local filing applies
Parent Surrogate Filing Surrogate Filing (i.e voluntary available? filing in parent jurisdiction)? X No
X
January 1, 2017
January 1, 2016
X
January 1, 2016
X
N/A
January 1, 2016
X
January 1, 2017
X
N/A
January 1, 2016
X
January 1, 2016
X
N/A
X
January 1, 2016
X
January 1, 2016
X
N/A
-
Not required
January 1, 2016
X
January 1, 2016
X
N/A
-
Not required
January 1, 2016
X
January 1, 2016
X
N/A
Not required
-
January 1, 2016
X
January 1, 2016
X
N/A
-
-
January 1, 2016
X
January 1, 2017
X
N/A
Denmark
X
Not required
January 1, 2016
X
January 1, 2017
X
N/A
France
X
-
January 1, 2016
X
January 1, 2016
X
N/A
Gabon
-
-
January 1, 2016
X
January 1, 2017
No
-
Germany
-
Not required
January 1, 2016
X
January 1, 2017
X
N/A
Guernsey
X
X
January 1, 2016
No
N/A
X
N/A
-
-
January 1, 2018
X
January 1, 2018
X
Yes
X
-
April 1, 2016
X
April 1, 2016
X
N/A
Chile Czech Republic
Hong Kong, China India
|Passion for Excellence|
23
CbC reporting frameworks (2/3) Jurisdiction
Indonesia
Primary law in place
First fiscal year covered for Secondary law filing by in place Ultimate Parent Entity
First fiscal period for which local filing applies
Local Filing required?
Parent Surrogate Filing Surrogate Filing (i.e voluntary available? filing in parent jurisdiction)?
Not required
-
January 1, 2016
X
January 1, 2016
X
N/A
Ireland
X
X
January 1, 2016
X
January 1, 2016
X
N/A
Isle of Man
X
-
-
-
-
-
-
Israel
-
-
January 1, 2016
-
-
-
N/A
Italy
X
-
January 1, 2016
X
-
-
N/A
Japan
X
X
April 1, 2016
X
April 1, 2016*
X
Yes
Jersey
X
-
January 1, 2016
X
January 1, 2016
X
N/A
Korea
-
-
January 1, 2016
X
January 1, 2016
X
N/A
Latvia
-
-
January 1, 2016
X
January 1, 2017
X
N/A
X**
-
January 1, 2017
X
January 1, 2017
X
Yes
Lithuania
-
-
January 1, 2016
X
January 1, 2017
X
N/A
Luxembourg
-
-
January 1, 2016
-
-
X
N/A
X
-
January 1, 2017
No
N/A
X
No
Not required
-
January 1, 2016
X
January 1, 2016
X
N/A
Mexico
X
-
January 1, 2016
X
January 1, 2016
X
N/A
Norway
X
X
January 1, 2016
X
January 1, 2017
X
Yes
Netherlands
X
X
January 1, 2016
X
January 1, 2016
X
N/A
Liechtenstein
Malaysia Malta
|Passion for Excellence|
* Japan provides transition relief for the fiscal year commencing between 1 April 2016 and 31 March 2017 except the case of Systemic Failure. ** Liechtenstein: Confirmed by Parliament in November 2016. Currently, within the referendum period.
24
CbC reporting frameworks (3/3) Jurisdiction
New Zealand Nigeria
First fiscal year covered for Primary law in Secondary law filing by place in place Ultimate Parent Entity Not required January 1, 2016
First fiscal period for which local filing applies
Local Filing required?
No
N/A
Parent Surrogate Filing Surrogate Filing (i.e voluntary available? filing in parent jurisdiction)? No N/A
-
-
-
X
January 1, 2017
X
Yes
People's Republic of China Poland
X
X
January 1, 2016
X
January 1, 2016
X
N/A
X
-
January 1, 2016
X
January 1, 2017
X
N/A
Portugal
X
-
January 1, 2016
X
January 1, 2016
X
N/A
Russian Federation Singapore
-
-
January 1, 2017
X
January 1, 2017
X
Yes
-
-
January 1, 2017
X
-
No
-
Slovak Republic
-
-
January 1, 2016
-
-
-
N/A
Slovenia South Africa
-
-
January 1, 2016
X
January 1, 2017
X
N/A
X
X
January 1, 2016
X
January 1, 2016
No
N/A
Spain
X
X
January 1, 2016
X
January 1, 2016
X
N/A
Sweden
-
-
January 1, 2016
X
January 1, 2016
X
N/A
Not required
January 1, 2018
X
January 1, 2018
X
Yes
X***
N/A
Switzerland
X****
Turkey
X
-
January 1, 2016***
United Kingdom
X
X
January 1, 2016
X
January 1, 2016
X
N/A
United States
X
X
June 30, 2016
No
N/A
No
Yes
Uruguay
-
-
January 1, 2017
X
January 1, 2017
X
No
*** Turkey: In order to start the implementation, secondary regulations have to be in place, drafts are published but they are not officially issued.
X***
|Passion for Excellence|
January 1, 2016***
**** Switzerland: Draft legislation sent to Parliament on 23 November 2016
25
Menara Kuningan, 12th & 15th Floor Jl. H.R. Rasuna Said Kav. 5 Blok. X-7 Jakarta Selatan 12940, Indonesia Tel : + 62 21 30015690 Fax : + 62 21 30015691 www.taxprime.net
26
Selected Countries implementation BEPS Action 13 PMK 213/2016
|Passion for Excellence|
2
What is Base Erosion and Profit Shifting (BEPS)? Tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity. Some of the schemes used are illegal, most are not. Undermines the fairness and integrity of tax systems only MNES can use BEPS to gain a competitive advantage over enterprises that operate at a domestic level.
Undermines voluntary compliance by all taxpayers.
|Passion for Excellence|
3
15 BEPS Actions Plans Action 2: Neutralising the Effects of Hybrid Mismatch Arrangements
Action 3: Designing Effective CFC regulations
Action 4: Limiting Base Erosion Involving Interest Deductions and Other Financial Payments
Action 5: Countering Harmful Tax Practices
Action 12: Mandatory Disclosure Rules
Action 11: Measuring and Monitoring BEPS
Actions 8-10: Aligning Transfer Pricing Outcomes with Value Creation
Action 7: Preventing the Artificial Avoidance PE
Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances
Action 13: Transfer Pricing Documentation and Country-by-Country Reporting
Action 14: Dispute Resolution Mechanisms
Action 15: Developing a Multilateral Instrument
Action 1: Addressing the Tax Challenges of the Digital Economy
|Passion for Excellence|
4
A three-tiered approach to TPD Country-byCountry Report (CbCR) Local File • Detailed intercompany transactions. • ALP Price testing
• Global allocation income, taxes, economic activities • NO ALP Price testing
Master File • “Blueprint” of the MNE group TP Policies • NO ALP Price testing
Split of information based on audiences
|Passion for Excellence|
5
Local File
WHAT • detailed information relating to specific intercompany transactions. PURPOSE • supplements the master file and assures taxpayer has complied with the ALP SCOPE • information relevant to the transfer pricing analysis related to TP transaction
|Passion for Excellence|
6
Local File No Subject 1 Identity and Business Activity
Description •
management structure
•
Business and business strategy
•
Operational aspects for Taxpayer’s business activity
•
overview of business environment
•
Transaction scheme and the explanation
•
Pricing policy applied in the last 5 (five) years
•
Explanation over each transactions
•
The transaction amount specified per transaction type and per counterparty
•
Details transactions for commodity products
•
Copy of the agreement
3 The application of the arm’s length principle •
comparability analysis
2 Information on Affiliated Transaction and independent transaction conducted by the Taxpayer
•
business characterization
•
Transfer Price Determinaion method
•
Tested party and PLI
•
summary of the assumptions used in the Transfer Pricing method
•
Comparables and TP Methods implemented
•
TP Analysis
•
copy of the Advance Pricing Agreement (APA) |Passion for Excellence|
7
Local File No
Subject
4 The Taxpayer’s Financial Information
5 Non-financial /facts affects the pricing or the profit level
Description •
Financial Statement
•
Segmented FS
•
the usage of informations in the financial report to the TP Methods
•
relevant financial informations from the comparables
•
-
|Passion for Excellence|
8
Master File WHAT • Overview of the MNE group business (Operations, TP Policies, Global allocation income and economic activity)
PURPOSE: • Evaluating the presence of significant transfer pricing risk • Providing with a high-level overview of the MNE’s global operations and policies. LEVEL OF DETAILS: • Important information should be presented. Important? if its omission would affect the reliability of the transfer pricing outcomes.
SCOPE: WHOLE VS LINE OF BUSINESS • Whole MNE, however, line of business is permitted (justification: e.g. where some significant business lines operate largely independently or are recently acquired). • BUT, the entire master file of all business lines should be available to each country. |Passion for Excellence|
9
Master File
5 level Information No
Subject
1 Organisational structure 2 Description of MNE’s business(es)
Description • Chart illustrating the MNE’s legal and ownership structure and geographical location of operating entities. • Important drivers of business profit; • Supply chain for the group’s five largest products and/ or service offerings by turnover plus any other products and/or services amounting to more than 5 percent of group turnover
• Important service arrangements between members of the MNE group, other than research and development (R&D) services, • A description of the main geographic markets for the group’s products and services that are referred to in the second bullet point above; • Functional analysis describing the principal contributions to value creation by individual entities within the group • Important business restructuring transactions, acquisitions and divestitures occurring during the fiscal year.
|Passion for Excellence|
10
Master File No Subject 3 MNE’s intangibles
Description • •
4 Financial activity and financing • in the Business Group • • • 5 The Consolidated Financial • Report of The Parent Entity and the taxation information in relation to Affiliated • transaction
MNE’s overall strategy for the DEMPE location of principal R&D, facilities and location of R&D management.
Explanation about financing conducted by the Business Group explanation about members of the Business Group carrying financial/financing center to the members, the country/jurisdiction where the Business Group members established and the effective management located Financing agreement between Business Group members Consolidated Financial Statement of the Business Group for the concerned Taxable Year (for external or internal interest)
Advance Pricing Agreement (APA) owns by members of the Business Group and other tax provisions
|Passion for Excellence|
11
CbCR WHAT • Aggregate tax jurisdiction-wide information of global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which the MNE group operates. • A listing of all the Constituent Entities for which financial information is reported PURPOSE
• High-level transfer pricing risk assessment purposes. • It may also be used by tax administrations in evaluating other BEPS related risks • Economic and statistical analysis.
|Passion for Excellence|
12
CbCR IMPORTANT NOTE • NOT a substitute for a detailed TP analysis of individual transactions • NOT conclusive evidence that appropriateness of TP • NOT to propose TP adjustments based on a global formulary apportionment of income.
|Passion for Excellence|
13
CbCR Overview of allocation of income, taxes and business activities by tax jurisdiction
|Passion for Excellence|
14
CbCR List of all the Constituent Entities of the MNE group included in each aggregation per tax jurisdiction
|Passion for Excellence|
15
Objectives of TPD
1.Taxpayer’s assessment of its compliance with the arm’s length principle
transfer pricing risk assessment
1.Enabling thorough TP audit 2.
Par. 5 of BEPS Report Action 13
|Passion for Excellence|
16
transfer pricing risk assessment
Contemporaneous documentation
WHAT? Documentation and information that taxpayers have relied upon to determine the TP 1. prior to or at the time of undertaking the transactions, or 2. in any event, no later than the time of completing and filing the tax return for the fiscal year in which the transaction takes place (Ex-Ante approach)
WHY? 1. Ensuring a culture of compliance. 2. Ensuring the integrity of the taxpayers’ positions and restrain taxpayers from developing justifications for their positions after the fact.
ISSUES 1. costs, time constraints, and competing demands for the attention of relevant personnel 2. Retroactive Adjusment |Passion for Excellence|
17
Ex-Ante vs Ex-Post Approach Fiscal Year Ex-ante: Price Setting Approach Forward Looking Presentation • Information available at the time when the intercompany transaction take place (ex: Comparable transactions from previous years, budget figures based on economic and market changes between the previous and tested year.) • Regular monitoring process between budget and actual figures required • No retroactive adjustments
• Documentation on the price setting process itself
Ex-post: Outcome Testing Approach Retroactive Adjustment • Information available at the time before closing of the books or before the tax return is filed (ex: Actual figures on revenues and cost structure) • Retroactive adjustments in order to achieve an arm’s length outcome • Documentation often based on database studies
|Passion for Excellence|
18
Compliance Issues
Materiality
• local file purposes, based on local conditions
Retention of documents
• Reasonable and consistent with domestic law
Frequency of documentation updates
• Annual update and review
Language
• Based on local law and commonly used language
|Passion for Excellence|
Penalties
• failure or nottimely submission: civil or administrative monetary penalties
Confidentiality
• No public disclosure
Other
• Local comparable is preferred, if available.
19
Implementation CbCR
Master file & Local File • Implemented through local country legislation
Timing: Beginning on or after 1 January 2016 Target:MNE groups with annual consolidated group revenue: preceding fiscal year of more than EUR 750 million or a equivalent amount in domestic currency as of January 2015 Principle: consistent, confidential, and proper use Automatic Exchange of Information Implementation package for government-to-government exchange of Country-by-Country Reports (Annex IV to Chapter V)
|Passion for Excellence|
20
World’s Income Tax Rates in 2016 |Below 25% (1/2) No 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
LOCATION Bahamas Bahrain Bermuda Bonaire, Saint Eustatius and Saba Cayman Islands Guernsey Isle of Man Vanuatu Montenegro Bosnia and Herzegovina Bulgaria Gibraltar Macedonia Paraguay Qatar Macau Moldova Oman Cyprus
% 0 0 0 0 0 0 0 0 9 10 10 10 10 10 10 12 12 12 12.5
|Passion for Excellence|
No 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39
LOCATION Ireland Liechtenstein Albania Georgia Iraq Kuwait Latvia Lebanon Lithuania Mauritius Serbia Sri Lanka Romania Hong Kong Singapore Slovenia Taiwan Switzerland Belarus Ukraine
% 12.5 12.5 15 15 15 15 15 15 15 15 15 15 16 16.5 17 17 17 17.92 18 18
World’s Income Tax Rates in 2016 |Below 25% (2/2) No
LOCATION
40
Czech Republic
41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58
Hungary Poland
Afghanistan Armenia Cambodia Croatia Estonia Fiji Finland Iceland Jersey Jordan Kazakhstan Libya Russia Saudi Arabia Thailand Turkey
No
LOCATION
19
59
United Kingdom
20
19 19 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20
60 61 62 63 64 65 66 67 68 69 70 71 72 73
Yemen Portugal Botswana Curacao Denmark Ecuador Slovakia Sweden Syria Vietnam Egypt Chile Malaysia Korea, Republic of
20 21 22 22 22 22 22 22 22 22 22.5 24 24 24.2
%
|Passion for Excellence|
%
22
CbC reporting frameworks (1/3)
Jurisdiction
Primary law in place
First fiscal year covered for Secondary law filing by in place Ultimate Parent Entity January 1, 2017
Argentina
-
Australia
X
X
Austria
X
Not required
Belgium
X
Brazil
X
Bulgaria Canada
Local Filing required?
First fiscal period for which local filing applies
Parent Surrogate Filing Surrogate Filing (i.e voluntary available? filing in parent jurisdiction)? X No
X
January 1, 2017
January 1, 2016
X
January 1, 2016
X
N/A
January 1, 2016
X
January 1, 2017
X
N/A
January 1, 2016
X
January 1, 2016
X
N/A
X
January 1, 2016
X
January 1, 2016
X
N/A
-
Not required
January 1, 2016
X
January 1, 2016
X
N/A
-
Not required
January 1, 2016
X
January 1, 2016
X
N/A
Not required
-
January 1, 2016
X
January 1, 2016
X
N/A
-
-
January 1, 2016
X
January 1, 2017
X
N/A
Denmark
X
Not required
January 1, 2016
X
January 1, 2017
X
N/A
France
X
-
January 1, 2016
X
January 1, 2016
X
N/A
Gabon
-
-
January 1, 2016
X
January 1, 2017
No
-
Germany
-
Not required
January 1, 2016
X
January 1, 2017
X
N/A
Guernsey
X
X
January 1, 2016
No
N/A
X
N/A
-
-
January 1, 2018
X
January 1, 2018
X
Yes
X
-
April 1, 2016
X
April 1, 2016
X
N/A
Chile Czech Republic
Hong Kong, China India
|Passion for Excellence|
23
CbC reporting frameworks (2/3) Jurisdiction
Indonesia
Primary law in place
First fiscal year covered for Secondary law filing by in place Ultimate Parent Entity
First fiscal period for which local filing applies
Local Filing required?
Parent Surrogate Filing Surrogate Filing (i.e voluntary available? filing in parent jurisdiction)?
Not required
-
January 1, 2016
X
January 1, 2016
X
N/A
Ireland
X
X
January 1, 2016
X
January 1, 2016
X
N/A
Isle of Man
X
-
-
-
-
-
-
Israel
-
-
January 1, 2016
-
-
-
N/A
Italy
X
-
January 1, 2016
X
-
-
N/A
Japan
X
X
April 1, 2016
X
April 1, 2016*
X
Yes
Jersey
X
-
January 1, 2016
X
January 1, 2016
X
N/A
Korea
-
-
January 1, 2016
X
January 1, 2016
X
N/A
Latvia
-
-
January 1, 2016
X
January 1, 2017
X
N/A
X**
-
January 1, 2017
X
January 1, 2017
X
Yes
Lithuania
-
-
January 1, 2016
X
January 1, 2017
X
N/A
Luxembourg
-
-
January 1, 2016
-
-
X
N/A
X
-
January 1, 2017
No
N/A
X
No
Not required
-
January 1, 2016
X
January 1, 2016
X
N/A
Mexico
X
-
January 1, 2016
X
January 1, 2016
X
N/A
Norway
X
X
January 1, 2016
X
January 1, 2017
X
Yes
Netherlands
X
X
January 1, 2016
X
January 1, 2016
X
N/A
Liechtenstein
Malaysia Malta
|Passion for Excellence|
* Japan provides transition relief for the fiscal year commencing between 1 April 2016 and 31 March 2017 except the case of Systemic Failure. ** Liechtenstein: Confirmed by Parliament in November 2016. Currently, within the referendum period.
24
CbC reporting frameworks (3/3) Jurisdiction
New Zealand Nigeria
First fiscal year covered for Primary law in Secondary law filing by place in place Ultimate Parent Entity Not required January 1, 2016
First fiscal period for which local filing applies
Local Filing required?
No
N/A
Parent Surrogate Filing Surrogate Filing (i.e voluntary available? filing in parent jurisdiction)? No N/A
-
-
-
X
January 1, 2017
X
Yes
People's Republic of China Poland
X
X
January 1, 2016
X
January 1, 2016
X
N/A
X
-
January 1, 2016
X
January 1, 2017
X
N/A
Portugal
X
-
January 1, 2016
X
January 1, 2016
X
N/A
Russian Federation Singapore
-
-
January 1, 2017
X
January 1, 2017
X
Yes
-
-
January 1, 2017
X
-
No
-
Slovak Republic
-
-
January 1, 2016
-
-
-
N/A
Slovenia South Africa
-
-
January 1, 2016
X
January 1, 2017
X
N/A
X
X
January 1, 2016
X
January 1, 2016
No
N/A
Spain
X
X
January 1, 2016
X
January 1, 2016
X
N/A
Sweden
-
-
January 1, 2016
X
January 1, 2016
X
N/A
Not required
January 1, 2018
X
January 1, 2018
X
Yes
X***
N/A
Switzerland
X****
Turkey
X
-
January 1, 2016***
United Kingdom
X
X
January 1, 2016
X
January 1, 2016
X
N/A
United States
X
X
June 30, 2016
No
N/A
No
Yes
Uruguay
-
-
January 1, 2017
X
January 1, 2017
X
No
*** Turkey: In order to start the implementation, secondary regulations have to be in place, drafts are published but they are not officially issued.
X***
|Passion for Excellence|
January 1, 2016***
**** Switzerland: Draft legislation sent to Parliament on 23 November 2016
25
Menara Kuningan, 12th & 15th Floor Jl. H.R. Rasuna Said Kav. 5 Blok. X-7 Jakarta Selatan 12940, Indonesia Tel : + 62 21 30015690 Fax : + 62 21 30015691 www.taxprime.net
26
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