European Commission opens in-depth investigation into Netherlands tax rulings
On 10 January 2019 the European Commission announced that it has opened an in-depth investigation into tax rulings granted by the Netherlands to companies in the Nike group. The rulings may have given the companies an unfair competitive advantage
See MoreIndia: CBDT notifies rule for secondary adjustments in transfer pricing
The CBDT has notified a new "Income Tax Rule 10CB" which stipulates a deadline for the reimbursement of excess money (90 days) and the applicable interest rate (separate interest rates for transactions in INR / foreign currency) taken into account
See MoreJapan: Published Frequently Asked Questions regarding transfer pricing documentation requirements
Japan’s National Tax Agency (NTA) has issued Frequently Asked Questions (FAQs) regarding transfer pricing (TP) documentation requirements in Japan. It addresses those questions that are likely to be of most interest to overseas headquartered
See MoreIreland: State aid investigation of TP rulings
The final decision of European Commission (EC) was published this week on its state aid investigations into Transfer Pricing (TP) rulings granted by Ireland to a US multinational group. Although the decision was announced in August 2016, publication
See MoreUK: Consultation on secondary adjustments in transfer pricing legislation
On 26 May 2016 the UK has published a consultation document on the possible introduction of secondary adjustments into the UK transfer pricing legislation. This would in the opinion of the UK government help to ensure taxpayer compliance with the
See MoreSouth Africa: Transfer Pricing Adjustments Regarding Withholding Tax Obligations
Under the income tax act, section 31(3), South Africa provide that any adjusted amount for transfer pricing and thin capitalization purposes, prior to 1 January 2015, constituted a deemed loan. The adjusted amount plus interest deemed to have
See MoreEU Joint TP Forum Publishes Member States’ Profiles
The European Union Joint Transfer Pricing Forum (JTPF) has issued descriptions of the transfer pricing systems of European Union (EU) member states in a standardized form, giving relevant information on aspects of the transfer pricing rules and tax
See MoreNigeria: Managing Transfer Pricing risks
The Nigerian transfer pricing rules are still relatively new, as detailed implementation of the transfer pricing law effectively began only with the release of the Transfer Pricing Regulations in 2012. Taxpayers must therefore make sure that they
See MoreEuropean Union: JTPF presents transfer pricing profiles of EU Member States
The EU Joint Transfer Pricing Forum (JTPF) has presented the transfer pricing profiles of all EU Member States. The profiles contain information about domestic transfer pricing frameworks, competent authorities’ contact details and other useful
See MoreIndia: Vodafone case regarding transfer pricing
The Bombay high court directed the income-tax department to stop the proceedings of its dispute resolution panel (DRP) against the Indian subsidiaries of Vodafone Group Plc and Royal Dutch Shell plc in an alleged transfer pricing case till the court
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