Global Transfer Pricing Country-by-Country Report November update - Tax and Legal blog

Banner Blog 27.11.19 (2)
Multinational companies are operating in an environment of unprecedented complexity. The rising volume and variety of intercompany transactions and transfer pricing regulations, coupled with increased tax authority collaboration across borders present both risks and opportunities. Our transfer pricing updates will provide you with the latest transfer pricing issues and developments worldwide that may affect your business.

November deadlines for global transfer pricing documentation and Country-by-Country Reporting

The following countries have upcoming November statutory deadlines for country-by-country reporting (CbCR) notifications, CbC reports, master files, or local files.

(The due dates below assume a 31 December year-end)

Guernsey

CbCR notification for 2018 tax year. For resident constituent entities that are not ultimate parent entities or surrogate parent entities, CbCR notifications in Guernsey are due by 30 November in the year following the last day of the relevant fiscal year.

India

Master file for 2018/2019 tax year. The master file must be filed by the tax return due date, which is 30 November following the end of the relevant fiscal year.

Local file for 2018/2019 tax year. The local file must be contemporaneously prepared by the tax return due date, which is 30 November following the end of the relevant fiscal year.

Italy

CbCR notification for 2018 tax year. CbCR notifications in Italy are included in the annual tax return and are due on the annual tax return’s filing date, which is 11 months after the tax year-end.

Master file and Local File for 2018 tax year. The master file and local file must be contemporaneously prepared by the annual tax return’s filing date, which is 11 months after the tax year-end, to receive penalty protection.

Singapore

Local file for 2018 tax year. The local file must be contemporaneously prepared by the tax return due date, which is 30 November following the end of the relevant fiscal year.

Sri Lanka

Local file for 2018 tax year. The local file must be contemporaneously prepared by the tax return due date, which is 30 November following the end of the relevant assessment year.

Deloitte's Transfer Pricing practice has prepared the Global Tax Reset - Transfer Pricing Documentation Summary, which compiles essential country-by-country reporting and documentation information (including master file/local file information, if applicable) for 122 jurisdictions around the world.

More information is available on our website page

For more information regarding transfer pricing issues in specific countries, and about Deloitte’s tax practice in those jurisdictions, please contact your usual Deloitte transfer pricing advisor or one of the listed contacts below.

Key Contacts

Raoul Stocker_BLOG

Raoul Stocker - Partner, International Tax 

Raoul Stocker is a tax partner with more than 15 years’ experience specifically in international tax litigation such as mutual agreement procedures and advanced pricing agreements. His focus lies on corporate tax planning, cross-border structuring of corporate transactions and businesses, transfer pricing as well as taxation of financial institutions. Raoul is also a lecturer of transfer pricing and tax law at the University of St. Gallen.

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Habermacher_Blog

Hans Rudolf Habermacher - Partner, Transfer Pricing Leader Switzerland

Hans Rudolf has over 17 years’ of experience in advising clients in Transfer Pricing concepts. He successfully engages with MNCs in various industries in the planning, implementation, documentation & defence of TP concepts. Further he has significant experience in the design and implementation of principal & licensing structures. He is also highly successful in filing and negotiating bilateral APA's (Advanced Pricing Agreements) and mitigating double taxation issues through MAP procedures.

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 Lorenzo Mondin_blog

Lorenzo Mondin - Manager, Transfer Pricing

Lorenzo works on Swiss and international engagements focusing on advisory projects mostly in relation to intra-group transfer pricing policies, corporate restructurings, intra-group debt, fiscal due diligences and tax audits whilst contributing to a certain number of compliance projects in relation to global transfer pricing documentation engagements. A large part of his client portfolio includes multinational groups active in the energy and resources sector, financial sector and life-science sector.

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