Posts by admin

Transfer Pricing Brief: October 2012

March 6, 2013

Chile The main corporate income tax rate is 20% for 2012. Under Law 20,630 amending the transfer pricing rules where...

Transfer Pricing Brief: September 2012

March 5, 2013

Australia A new subdivision 815-A has been passed in 2012 in respect of treaty equivalent cross-border transfer pricing rules. The...

UK: Protocol to the double tax agreement with China

March 5, 2013

A protocol to the treaty between the UK and China was signed on 27 February 2013. This protocol amends the...

Malta and Norway DTA enters into force

March 5, 2013

A double tax agreement (DTA) between the Government of Malta and the Norwegian Government, signed on 30 March 2012, entered...

Poland – Changes to transfer pricing documentation, thin capitalization rules

March 5, 2013

Legislation to expand the scope of Poland’s corporate income tax law is intended to be effective in 2014. The provisions...

OECD: report on tax evasion through electronic sales suppression

March 5, 2013

In both electronic and manual accounting systems the arrangements for recording cash received at the point of sale are important...

EU: ECJ Rules on German foreign tax credit rules

March 5, 2013

The European Court of Justice (ECJ) issued a decision on 28 February 2013 in the case of Dr. Manfred Beker and...

India: Budget for 2013

March 5, 2013

According to the Indian Budget 2013, the Government is considering for following major tax initiatives: the introduction of a Direct...

Greece: Introduction of new Advance Pricing Agreement and Improvements of transfer pricing framework

March 5, 2013

Tax Law 4110/2013 was circulated in the Govt. Gazette on 23th January 2013. Aside from some major amendments on taxation...

Portuguese Court’s decision in transfer pricing dispute relating to inter-company loan and management fees

February 27, 2013

The arbitration administrative court in Portugal recently ruled in favour of the taxpayer in a dispute with the Portuguese Tax Authorities (TA)...

United States: IRS publishes quarterly list of individuals who have expatriated.

February 27, 2013

The US Internal Revenue Service has published a quarterly notice with a list of US citizens and long-term US residents...

Japan: For 2013 tax reform proposals

February 27, 2013

The Tax Commission of Japan has submitted 2013 tax reform proposal on January 29, 2013 upon approval by the Cabinet....

Treaty between Finland and Uruguay enters into force

February 27, 2013

The Income and Capital Tax Treaty between Finland and Uruguay entered into force on 6 February 2013. The treaty generally...

Chile: New Transfer Pricing Compliance Requirement

February 27, 2013

A new transfer pricing compliance requirement has been introduced in Chile by Resolution No. 14 of 2013. According to the...

Australia: New Transfer Pricing Legislation

February 27, 2013

On 13 February 2013, the Federal Government introduced legislation on 13 February containing new Australian Transfer Pricing Laws.  These are largely consistent...

Treaty between US and Poland signed

February 24, 2013

United States has signed an Income Tax Treaty (2013) with Poland on 13 February 2013 which will replace the existing...

Russia: Amendments to Tax Code regarding corporate property tax

February 24, 2013

Russian Federal Law No. 202-FZ, issued on November 29, 2012, amended the Tax Code by introducing additional exemptions from corporate...

Philippines: New Transfer Pricing Regulations

February 24, 2013

The Philippines’ Secretary of Finance issued Revenue Regulations (RR) No. 02-2013 – the transfer pricing regulations – on 23 January...