| Australia | Transfer pricing rule-The practice statement (PS LA 2015/3) issued on 26 February 2015 sets out a new internal approval process for application of the reconstruction provisions. |
| See the Story in Regfollower | |
| Canada | Comparable data-Transfer Pricing Memorandum No.16 dated January 29, 2015, acknowledges number of areas where it may be useful to consider multiple years of data for establishing comparability. |
| See the Story in Regfollower | |
| India | Small and medium enterprises – The threshold limit for domestic transfer pricing rules has been increased from INR 50 million to INR 200 million equivalents to USD 3.24 million, in 2015 budget. |
| Audit Process: The Central Board of Direct Taxes has set up a separate transfer pricing cell for conducting transfer pricing audit. | |
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| Advance pricing agreement-The Finance (No.2) Act, 2014 introduced the rollback provisions under the Advance Pricing Agreement (APA) program. The rules have been notified [Notification 23/2015 (F.No.142 /14/2014-TPL]/ SO 758(E)] on 14 March 2015 setting out the applicability and the requirement for applying rollback. The APAs can now be rolled-back for a period of 4 previous years subject to certain conditions. | |
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| Germany | Arm’s length principle-The Upper House of the German Parliament has approved the regulations on the application of the arm’s length principle to profit allocations between head office and permanent establishments, which follow the authorized OECD approach (AOA) and is applicable from January 2015. |
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| Spain | BEPS action plan-The documentation recommendations from the BEPS action plan have been included in the published draft of the new Corporate Income Tax Regulations (CITR) including master file, country file and country-by-country reporting. The draft regulations also include the formal requirements for the cost-sharing agreements, the procedure for the relief of the secondary adjustment and the procedural regulations applying to unilateral/bilateral/multilateral APA’s. |
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| Vietnam | Specific transfer pricing compliance -As per prior guidance of Ministry of Finance, taxpayers need to use Form 03-7/TNDN to disclose E15 related-party transactions from the tax period beginning 1 January 2014. Tax authority issued Form 03-7/TNDN as a new form which replaces existing Form GCN-01/QLT. |
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| Taiwan | Arm’s length principle-The draft transfer pricing amendments to rules (Tai Cai Shui No. 10304651710) released on 7 January 2015 proposes mandatory application of arm’s length principle in the attribution of profits in a business restructuring provided some factors are taken into account in determining profits. A reasonable set-offs and considerations also proposed for controlled transactions after business restructuring. |
| Requirement of application for a pre-filing meeting-Requirement of application for a pre-filing meeting and providing required information before filing an advance pricing arrangement (APA) was proposed in draft transfer pricing amendments to rules. | |
| See the Story in Regfollower |
