Filing and Submission of CbCR and its Notification Letter

PER-29 introduces the requirements for certain Taxpayers to provide a CbCR notification letter (as stipulated within Appendix B of PER-29).  The CbCR notification letter aims to provide information to the DGT whether or not Taxpayers would be required to prepare and file a CbCR to the DGT.

A Taxpayer is required to submit a CbCR notification letter if the Taxpayer is either regarded as a constituent entity of an MNE or the taxpayer conducts related party transaction(s).  With regard to the preparation of the CbCR, PER-29 also specifically stipulates that under certain circumstances, the CbCR should be prepared electronically i.e., with Extensible Markup Language (XML).

The CbCR and/or its notification letter should be submitted to the DGT at the latest 16 months after the end of the fiscal year for fiscal year 2016, and 12 months after the end of the fiscal year for fiscal year 2017 onwards.

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