Obligation for taxpayers to report related-party transactions in Spain, Hungary moves towards implementation of BEPS Action 13, Cambodia signs its first Double tax treaty

Local tax news

​Slovak Republic - Implementation of Anti-Tax Avoidance Directive – Approved by Government
The government has approved the bill that implements Anti-Tax avoidance measures as provided in ATAD (EU Council Directive 2016/1164). The main provisions includes changes in “patent box” regime, exit taxation and CFC legislation. The new law will enter in force 1 January 2018, CFC rules will be effective from 1 January 2019.
 
Spain - New Obligation for Taxpayers to Report Related-Party Transactions
A new ministerial order has been issued that requires corporate taxpayers to report transactions between related parties in the jurisdictions that are identified as “tax havens”. Reporting obligation applies retroactively for the time period from 1 January 2016.
 
Sri Lanka - New Income Tax Law
The Parliament passed the new income tax law that will provide increased certainty for investors and taxpayers.
One of the important modifications for corporate taxpayers are changes in currently existing tax rates that be merged in three main groups:

• standard corporate income tax (28%);
• trust industries (14%); and
• liquor, tobacco and gaming companies (40%)
  
  

The new tax rates will be in effect from 1 April 2018.

BEPS news

​Argentina - CbC reporting - Schedule and Instructions Published
The Federal Tax Administration has published the regulatory framework (General Resolution 4130-E ) for country-by-country (CbC) reporting applicable to fiscal years commencing on or after 1 January 2017. The rules entered into force on 20 September 2017 and apply to:
 

• ultimate parent entities which had annual revenue of EUR EUR 750,000,000 or more for the previous reporting period, or
• surrogate parent entities with a net worth of at least ARS 50,000,000. 
  
  

As regards the information to be included in the CbC report and the confidentiality restriction for the use of that information, the rules adhere to the OECD standards. The CbC report must be filed electronically no later than the last working day of the twelfth month following the fiscal year of the relevant reporting period.
 
Hungary - Implementation of BEPS Action 13 – Draft Law Published
Draft legislation implementing transfer pricing documentation requirements in line with BEPS Action 13 has been published by the Hungarian government. The draft legislation introduces the Master file and Local file documentation requirements in addition to the applicable country-by-country reporting requirements. 
The three-tiered on transfer pricing documentation is in line with the OECD standards and will apply to resident companies as well as permanent establishments of non-resident

Treaty news

Cambodia - Thailand
On 7 September 2017, Cambodia and Thailand signed a tax treaty in Phnom Penh. Further developments will be reported as they occur.

Estonia - Japan
On 30 August 2017, the Estonia - Japan Income Tax Treaty (2017) was signed in Tallinn.
Further developments will be reported as they occur.
 
Kuwait - Turkey
On 14 September 2017, Kuwait and Turkey signed an amending protocol to update the Kuwait - Turkey Income and Capital Tax Treaty (1997), in Ankara. Further developments will be reported as they occur.

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