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BEPS Action 13 - tax.kpmg.us

beps Action 13: Country implementation summary Last updated: December 20, 2019. 2019 KPMG International Cooperative ( KPMG International ), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis- -vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved. 0. Country-by-Country Reporting: Country implementation summary Andorra Japan Kenya Argentina Jersey Turkey Australia Kazakhstan Ukraine Key: Implemented Draft bills Intentions to implement No development Austria Latvia Botswana Belgium Liechtenstein Georgia Total Count: 79 Countries 5 Countries 7 Countries Bermuda Lithuania Namibia Bosnia and Luxembourg Panama Herzegovina (Fed. Malaysia Rwanda of Bosnia and Malta Trinidad & Tobago Herzegovina) Mauritius Uganda British Virgin Mexico Islands Monaco Brazil Netherlands Bulgaria New Zealand Canada Nigeria Cayman Islands Norway Chile Pakistan China Papua New Guinea Colombia Peru Costa Rica Poland C te d'Ivoire Portugal Croatia Qatar Curacao Romania Cyprus Russia Czech Republic Saudi Arabia Denmark Singapore Egypt Slovenia Estonia Slovakia Finland South Africa France South Korea Gabon Spain Germany Sri Lanka Gibraltar Sweden Greece Switzerland Guernsey Taiwan Hong Kong United Kingdom Hunga

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Transcription of BEPS Action 13 - tax.kpmg.us

1 beps Action 13: Country implementation summary Last updated: December 20, 2019. 2019 KPMG International Cooperative ( KPMG International ), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis- -vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved. 0. Country-by-Country Reporting: Country implementation summary Andorra Japan Kenya Argentina Jersey Turkey Australia Kazakhstan Ukraine Key: Implemented Draft bills Intentions to implement No development Austria Latvia Botswana Belgium Liechtenstein Georgia Total Count: 79 Countries 5 Countries 7 Countries Bermuda Lithuania Namibia Bosnia and Luxembourg Panama Herzegovina (Fed. Malaysia Rwanda of Bosnia and Malta Trinidad & Tobago Herzegovina) Mauritius Uganda British Virgin Mexico Islands Monaco Brazil Netherlands Bulgaria New Zealand Canada Nigeria Cayman Islands Norway Chile Pakistan China Papua New Guinea Colombia Peru Costa Rica Poland C te d'Ivoire Portugal Croatia Qatar Curacao Romania Cyprus Russia Czech Republic Saudi Arabia Denmark Singapore Egypt Slovenia Estonia Slovakia Finland South Africa France South Korea Gabon Spain Germany Sri Lanka Gibraltar Sweden Greece Switzerland Guernsey Taiwan Hong Kong United Kingdom Hungary United States Iceland Uruguay India Vietnam Indonesia United Arab Ireland Emirates Isle of Man Bahamas Italy Israel 2019 KPMG International Cooperative ( KPMG International ), a Swiss entity.

2 Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis- -vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved. 1. Source: KPMG International member firms Master File / Local File: Country implementation summary Argentina (MF only) Spain Australia Sri Lanka Austria Sweden Key: Implemented Draft bills Intentions to implement No development Belgium Taiwan Bosnia and United Kingdom Total Count: 47 Countries 4 Countries 12 Countries Herzegovina Uruguay (MF only). (Federation of Vietnam Bosnia and Zambia Herzegovina) Bulgaria China Israel Colombia Turkey Costa Rica Ukraine (MF only). Curacao Botswana Denmark Chile (LF only). Egypt Greece Finland Isle of Man France Kenya Gabon Malaysia (MF only). Germany Namibia Hong Kong Portugal Hungary Rwanda India (MF only) Switzerland Indonesia Thailand (LF only).

3 Japan Uganda Kazakhstan Latvia Liechtenstein Lithuania Malaysia Mexico Netherlands New Zealand Nigeria Norway Pakistan Panama Peru Poland Russia Saudi Arabia Slovakia South Africa South Korea 2019 KPMG International Cooperative ( KPMG International ), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis- -vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved. 2. Source: KPMG International member firms Americas: beps Action 13 Implementation Key: Implemented Draft bills Intentions to implement No development Total CbCR: 14 Countries 1 Country 2 Countries Total MF/LF: 8 Countries 1 Country Canada Bermuda CbCR. final legislation CbCR. final legislation United States CbCR Cayman Islands final legislation CbCR.

4 Final legislation Mexico CbCR/MF/LF. Curacao final legislation CbCR/MF/LF. final legislation Bahamas CbCR British Virgin Islands draft Legislation CbCR. final legislation Costa Rica Trinidad &Tobago CbCR/MF/LF. final legislation CbCR. intentions Panama Colombia CbCR MF/LF CbCR/MF/LF. intentions final final legislation Peru Brazil CbCR/MF/LF CbCR. final legislation final legislation Chile Uruguay CbCR LF CbCR/MF. final intentions final legislation Argentina CbCR/MF. final legislation 2019 KPMG International Cooperative ( KPMG International ), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis- -vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved. 3. Source: KPMG International member firms Europe: beps Action 13 Implementation Key: Implemented Draft bills Intentions to implement No development Total CbCR: 39 Countries 1 Country Total MF/LF: 17 Countries 2 Countries 4 Countries Norway Denmark Germany CbCR/MF/LF.

5 Sweden CbCR/MF/LF. CbCR/MF/LF CbCR/MF/LF. Finland Switzerland CbCR/MF/LF. Estonia CbCR MF/LF Iceland Latvia CbCR. CbCR. CbCR/MF/LF. Luxembourg CbCR Netherlands Lithuania Poland CbCR/MF/LF. CbCR/MF/LF. CbCR/MF/LF. Belgium Czech Repl. CbCR/MF/LF. CbCR. Slovakia CbCR/MF/LF Austria Isle of Man CbCR/MF/LF. CbCR/MF/LF. CbCR MF/LF. Ukraine Ireland Hungary CbCR/MF. Guernsey CbCR. CbCR/MF/LF. CbCR. Romania CbCR Bulgaria Jersey CbCR MF/LF. CbCR France Andorra Bosnia&H. CbCR/MF/LF CbCR. Cyprus CbCR/MF/LF. Portugal CbCR. MF/LF Greece CbCR Croatia Gibraltar Spain Monaco Liechtenstein Italy Malta Slovenia CbCR MF/LF. CbCR. CbCR CbCR/MF/LF CbCR CbCR/MF/LF CbCR CbCR CbCR. Source: KPMG International member firms 2019 KPMG International Cooperative ( KPMG International ), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis- -vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.

6 All rights reserved. 4. Source: KPMG International member firms Africa & Middle East: beps Action 13 Implementation Key: Implemented Draft bills Intentions to implement No development Total CbCR: 9 Countries 2 Countries 4 Countries Total MF/LF: 6 Countries 1 Country 4 Countries Israel CbCR/MF/LF. draft legislation Nigeria CbCR/MF/LF Egypt final CbCR/MF/LF. final legislation Cote d'Ivoire UAE. CbCR CbCR. final legislation final legislation Qatar Gabon CbCR. final legislation CbCR/MF/LF. final legislation Saudi Arabia CbCR/MF/LF. Zambia final legislation MF/LF. final legislation Uganda CbCR/MF/LF. intentions Botswana CbCR/MF/LF Kenya intentions CbCR MF/LF. draft intentions Namibia Rwanda CbCR/MF/LF. intentions CbCR/MF/LF. intentions South Africa Mauritius CbCR/MF/LF CbCR. final legislation final legislation 2019 KPMG International Cooperative ( KPMG International ), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International.

7 KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis- -vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved. 5. Source: KPMG International member firms Asia Pacific: beps Action 13 Implementation Russia Key: Implemented Draft bills Intentions to implement No development CbCR/MF/LF. final legislation Total CbCR: 17 Countries 1 Country 1 Country Total MF/LF: 15 Countries 1 Country 2 Countries Japan Kazakhstan CbCR/MF/LF. CbCR/MF/LF. final legislation final legislation South Korea Georgia CbCR/MF/LF. CbCR final legislation intentions China CbCR/MF/LF. Turkey final legislation CbCR/MF/LF. draft legislation Sri Lanka CbCR/MF/LF. Pakistan final legislation CbCR/MF/LF. final legislation Taiwan CbCR/MF/LF. final legislation India CbCR/MF. final legislation Hong Kong CbCR/MF/LF. final legislation Vietnam CbCR/MF/LF Thailand final legislation LF.

8 Intentions Malaysia Papua New Guinea CbCR/LF MF. final intentions CbCR. final legislation Singapore Australia CbCR. CbCR/MF/LF. final legislation final legislation Indonesia New Zealand CbCR/MF/LF CbCR/MF/LF. final legislation final legislation 2019 KPMG International Cooperative ( KPMG International ), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis- -vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved. 6. Source: KPMG International member firms Countries with final and draft legislation /. Regulations / Public Discussion draft 2019 KPMG International Cooperative ( KPMG International ), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International.

9 KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis- -vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved. 7. Implemented Intention to implement Draft bills / public discussion No announcements made to date / not required Country Reporting Requirements Filing Requirements / Dates / Exemptions / Penalties CbyC Master File Local File Andorra Country-by-country reporting -Applies to MNEs with annual consolidated group revenue equal to or exceeding 750 million in the previous year. Regulations extend to subsidiary entities. -Applies for fiscal years beginning on or after 1 January 2018. -Must be filed within 12 months following the fiscal year-end. -Language and submission requirements have not been determined yet. -It has not been determined yet if entities can act as a surrogate. -The CbC notification must be filed by the corporate income tax return deadline for the reporting fiscal year.

10 -The penalties for failing to comply with the CbC requirements (either CbC reporting or CbC notification) are 1,000 for the first offence and 3,000 for subsequent offences. 2019 KPMG International Cooperative ( KPMG International ), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis- -vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved. 8. Implemented Intention to implement Draft bills / public discussion No announcements made to date / not required Country Reporting Requirements Filing Requirements / Dates / Exemptions / Penalties CbyC Master File Local File Argentina Country-by-country reporting -Applies to MNEs with annual consolidated group revenue equal to or exceeding 750 million in the previous year.


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