Automatic exchange of information - Tax rulings and advance pricing agreements
Law no. 98/2017, of 24 August was officially published, entering into force on 25 August, which:
- Regulates the automatic exchange of information mechanisms regarding tax rulings and advance pricing agreements, transposing Council Directives (EU) 2015/2376, of 8 December 2015 and (EU) 2016/881 of 25 May 2016;
- Amends the tax penalty for lack or delay in filing the transfer pricing file, introducing a 5% additional penalty for each day of delay;
- Introduces changes to the tax statement to be presented by Corporate taxpayers within multinational groups, clarifying its scope;
- Introduces a 4 year lifespan for tax rulings, which may be renewed by request. In addition, tax rulings should now be accompanied when presented with the necessary elements for the automatic exchange of information (in the cases and terms applicable as per the newly introduced changes);
- Establishes the 2015 final report on OECD/G20 BEPS Action 13 as auxiliary interpretation basis for the changes introduced.
Contacts
