Transfer Pricing Brief: April 2016
Portugal: General rule for CbC reporting requirement: Portugal has introduced Country-by-Country (CbC) reporting requirement for domestic entities with consolidated group revenue of €750 million or more for an accounting period. The CbC report
See MoreTransfer Pricing Brief: March 2016
India: General rule for CbC reporting requirement: India has proposed in the 2016 Union Budget to introduce the country-by-country reporting rules pursuant to the OECD’s three-tier transfer pricing documentation approach. Multinational groups
See MoreTransfer Pricing Brief: February 2016
Taiwan: Transfer Pricing Rules: As per the amendments to the Regulations governing assessment of profit-seeking enterprises, it is mandatory to apply the arm's length principle in the attribution of profits in a business restructuring provided
See MoreTransfer Pricing Brief: January 2016
Norway: Base Erosion and Profit Shifting (BEPS) Related Compliance: General Rule for Country by Country (CbC) Reporting: The Ministry of Finance published a public consultation paper regarding country-by country reporting for tax purposes. As per
See MoreTransfer Pricing Brief: December 2015
Mexico: Financial Services: Interest-accruing debts incurred in constructing, operating or maintaining production infrastructure linked to strategic areas in Mexico will not subject to the thin capitalization rules. Base Erosion and Profit
See MoreTransfer Pricing Brief: November 2015
Greece: Documentation requirement: Transfer pricing documentation requirements as set out by the Income Tax Code and the Procedural Code do not apply in respect of transactions made by real estate investment companies as per the clarification
See MoreTransfer Pricing Brief: October 2015
UK: CbC reporting requirement: UK has published draft Regulations in relation to Country by Country (CbC) reporting, along the lines of the recommendations made in the OECD action plan on base erosion and profit shifting (BEPS). The Regulations
See MoreTransfer Pricing Brief: September 2015
Ukraine: Comparable uncontrolled price method (“CUP”): As per the new law which came into force from August 11 2015, taxpayers are allowed to use Comparable Uncontrolled Price (“CUP”) method only with reference to the prices on the
See MoreTransfer Pricing Brief: August 2015
Australia: Documentation requirement: The Australian Treasury has released exposure draft law on 6 August 2015 to implement the new OECD standards on transfer pricing documentation like master file which will include an overview of the
See MoreTransfer Pricing Brief: July 2015
India: Comparable data range: The Punjab and Haryana High Court confirmed a judgment in the case of CIT-I v. DSM Anti Infectives India Ltd. ITA No. 116 of 2014 of a tax appellate tribunal that certain companies could be appropriate
See MoreTransfer Pricing Brief: June 2015
India: Intangible property: The Delhi High Court ruling on marketing intangibles in the Sony Ericsson Mobile Communications India Pvt. Ltd. case provides clear guidance on how the issue of marketing intangibles should be viewed in cases where
See MoreTransfer Pricing Brief: May 2015
India: Comparable Data Range: The company having high or extremely high profits and losses should not be the only consideration to exclude as a comparable company for purposes of determining the arm’s length price but other matters like
See MoreTransfer Pricing Brief: April 2015
UK: BEPS Country-by-Country Reporting Requirement: Clause 122 of the Finance Bill gives the UK Treasury the power to make regulations for implementing the guidance of the OECD on country-by-country reporting. This would be part of the transfer
See MoreTransfer Pricing Brief: March 2015
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
See MoreTransfer Pricing Brief: February 2015
France Penalty for Documentation FailureThe Finance Act, 2015 provides that for tax audits initiated from 1 January 2015 penalties for inadequate documentation are the higher of EUR 10,000 per entity per period under audit; 0.5% of the total
See MoreTransfer Pricing Brief: January 2015
Australia Requirement for Transfer Pricing Documentation- Taxpayers with a high risk transfer pricing profile will be held to more stringent requirements. Transfer Pricing Audits Penalty in Cases of Adjustments-25% penalty applies
See MoreTransfer Pricing Brief: December 2014
Argentina Compliance-Decree 2103/2014 created a special unit to monitor cross-border trade and coordinate the work of the various government bodies to ensure the correct application of the law on international trade. Australia Transfer
See MoreTransfer Pricing Brief: November 2014
Australia Transfer Pricing Rule-The reconstruction provisions are contained in section 815-130 ITAA 1997. TR 2014/6 gives guidance on identifying situations where the form of commercial or financial relations differs from the
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