Transfer Pricing Brief: July 2013
Australia TPA Rule- New subdivisions 815-B to 815-E ITAA 1997 was enacted on 2 July 2013. Brazil Applicable Methods- Updates on applicable methods for import transactions. Germany TPA Rule-Legislation passed on 29 June 2013 and effective
See MoreWTO: 2013 World Trade Report
The World Trade Report for 2013 issued by the World Trade Organization (WTO) emphasizes that the development of world trade will be determined by a number of economic policies and social trends including shifts in patterns of production and
See MoreUN releases handbook on selected issues in administration of tax treaties
The United Nations Handbook on selected issues in the administration of tax treaties was issued on 28 June 2013. This follows a technical meeting held in New York on 30 to 31 May by the Financing for Development office of the UN’s Department of
See MoreUK: Finance Act 2013 receives the Royal Assent
The 2013 Finance Act became law on 17 July 2013. The main provisions include a reduction of the corporate tax rate from 22% to 21% in 2014/15 and to 20% in 2015/16. The Act also includes the legislation introducing the General Anti Abuse Rule
See MoreTreaty between Singapore and Barbados signed
On 15 July 2013, the Income Tax Treaty between Barbados and Singapore was signed, in Singapore. The treaty will enter into force when the ratification procedures have been completed. Under the treaty a permanent establishment will exist if a
See MoreIndia: Treaty between India and Uruguay enters into force
The Income and Capital Tax Treaty between India and Uruguay entered into force on 21 June 2013. The treaty generally applies from 1 January 2014 for Uruguay and from 1 April 2014 for India. This treaty was signed in September 8, 2011. Under the
See MoreSingapore: planning changes on Exchange of Information regime
Ministry of Finance (MOF) of Singapore’s launched a public discussion regarding suggested modifications in the draft Income Tax (Amendment) Bill 2013 relating to the recent changes made to the Exchange of Information (EOI) regime. The Monetary
See MoreRussia: Variation in mineral tax rates
The upper chamber of Russian parliament approved draft Law No. 297807-6 on July 10, 2013 which changes the Federal Law on Customs Tariff and introduces a differentiation in mineral tax rates. The law changes the previous flat rate of tax on natural
See MorePoland: Amendments on transfer pricing guidelines come into force
The amendment of the Transfer Pricing Ordinance was published in the Official Journal No. 768/2013 on 3 July 2013, in a decree of Poland’s Ministry of Finance.The decree implements the provisions of the 2010 OECD Transfer Pricing Guidelines for
See MorePhilippines: New regulation on tax deduction in the event of failure to withhold tax
The Philippines issued Revenue Regulation 12-2013 (Rev. Reg. 12-2013) on 13 July 2013. Rev. Reg. 12-2013 is applicable to payments made to both domestic and foreign beneficiary and it will effective from 28 July 2013 for payments that are related
See MoreOECD releases action plan on base erosion and profit shifting
Further to the previous work by the OECD in respect of base erosion and profit shifting and the consideration of this work by the G8 group of countries, the OECD has now produced an action plan of measures to combat the shifting of profits across
See MoreNigeria: Tax implications for adopting IFRS
Under the IFRS regime, the circular proposes clarifications as to how specific assets, expenses, and income will be acted for tax motives. It also highlights the position of Nigerian tax authority on other issues, like the tax treatment of costing
See MoreNew Tax Treaty between China and Netherlands
The People’s Republic of China and the Netherlands signed a new tax treaty on 31 March 2013, which is expected to replace the current tax treaty of 1987. Under the new treaty, a building site, or construction, assembly or installation project or
See MoreNetherlands: Guidance on application of bonus deprecation rules (2013)
The Dutch tax authorities have given a clarification and cases showing examples of the new rules on “free depreciation” (or bonus depreciation) for businesses making new investments between 1 July and 31 December
See MoreTax treaty signed between Malta and Macau
The governments of Malta and Macau recently signed an agreement to work together to prevent tax evasion and tax avoidance. Macau is a part of the People’s Republic of China but operates as a separate jurisdiction for some purposes. It is expected
See MoreLuxembourg’s AIFM Directive-Bill adopted
The European Union’s Alternative Investment Fund Managers Directive has been amended by the draft legislation into Luxembourg law which was approved by the grand duchy’s Chamber of Deputies on Wednesday July 10, 2013. Luxembourg has become one
See MoreJapan: Changes in customs Valuation regulations
The customs valuation regulation has been changed in Japan. The valuation is based on the transaction value in line with World Trade Organization (WTO) rules but the change in the regulations clarifies the issue of which particular transaction is to
See MoreIndia: Decision on benchmarking international transactions
Recently the Income Tax Appellate Tribunal (“ITAT”) provides their decision regarding “standard analysis that every international transaction will have to be benchmarked and analyses separately by comparing it with independent uncontrolled
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