| Argentina | Resolución General N° 3476 introduced new Form F4501, for filing the transfer pricing documentation report. |
| Finland | Main corporate income tax rate has been reduced to 20%. |
| India | Circular 2/2013 clarifies that the profit split method is more suitable than the TNMM |
| Korea | The minimum tax rates applicable to corporations other than small and medium-sized companies are increased. |
| Namibia | Main corporate income tax rate changed. |
| Peru | As regards to the documentation format, under a draft resolution taxpayers would be required to submit the transfer pricing study to the SUNAT each year. |
| Russia | Updates on Financial Services, Documentation timing, Audits process and Advance Pricing Agreement. |
| Singapore | A corporate tax rebate of 30% will be given to all companies for 3 years from YA 2013 to YA 2015. |
TPA Newsletter
Argentina
Under Resolución General N° 3476 Form F4501 is used for filing the transfer pricing documentation report and requires digital signatures of the taxpayer, the CPA preparing the report and the professional association to which the CPA belongs.
Finland
Main corporate income tax rate, for the years 2014 to 2017 the tax rate is to be reduced to 20%.
India
Circular 2/2013 clarifies that the profit split method is more suitable than the TNMM for transactions involving intangible assets developed through research and development activities.
Korea
In relation to the main corporate income tax rate, a minimum tax applies to corporations that are not SMEs , Â are increased at the rates between 10% and 16%.
Namibia
Main corporate income tax rate, for 2013/14 the rate is 33% and from 2014/15 the rate is 32%.
Peru
As regards t the documentation Format, under a draft resolution taxpayers would be required to submit the transfer pricing study to the SUNAT each year with the Transfer Pricing Informative Return Form. If this proposal is passed, the transfer pricing study for 2012 should be sent to the SUNAT by July 2013.
Russia
Financial Services: The transfer pricing rules apply to intra-group financing arrangements including interest free loans. The rules do not apply to loans granted under agreements that were already in place before 1 January 2012, except where the conditions of the loan have been amended after that date.
Documentation-Timing-For documentation in respect of 2012 this deadline has been extended to 1 December 2013. For notification of transactions in 2012 this deadline has been extended to 20 November 2013.
Audits Process-Under Federal Law N227-FZ in force from 1 January 2012 specific transfer pricing audits are to be performed. Under transitional provisions, an audit for 2012 must be commenced by 31 December 2013(now extended to 30 June 2014) and an audit for 2013 must be commenced by 31 December 2014. After this, transfer pricing audits may cover the three years up to the year for which the audit is performed.
APAs-The Ministry of Finance has clarified that large taxpayers may apply for a bilateral or multilateral APA if the other countries involved have tax treaties with Russia.
Singapore
For the years 2013 to 2015 a corporate tax rebate of 30% of tax payable will be given, subject to a maximum of SGD 30,000 per year.
