Brazil and OECD present outline of new transfer pricing rules
On 12 April 2022 an event was held to present the outline of the new transfer pricing rules drafted by Brazil following a consultation process with the OECD. After Brazil had expressed the intention to become a full OECD member, Brazil and the
See MoreSlovenia updates the TP guidelines
On 31 January 2022, the Slovenian Ministry of Finance updated the transfer pricing (TP) guidelines. The revised guidance includes the new documentation requirements and procedures for determining income and transfer pricing, including for
See MoreSingapore publishes TP Guidelines on indicative margin for related-party loans
On 4 January 2022, the Singaporean Inland Revenue Authority updated transfer pricing guidelines to set the 2022 indicative margin at 1.8% for related-party loans. The indicative margins are applied on each related party loan not exceeding
See MoreOECD releases latest edition of the Transfer Pricing Guidelines
On 20 January 2022 the OECD released the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The latest edition of the guidelines includes changes made to the 2017 edition by reports issued by
See MoreUK: Responses to Consultation on Transfer Pricing Documentation
On 30 November 2021 the UK government published a summary of responses to the consultation on transfer pricing documentation held earlier in 2021. The original consultation invited comments from interested parties on whether there should be a
See MoreAustria releases the new transfer pricing guideline for 2021
On 7 October 2021, the Austrian Ministry of Finance published the updated Austrian Transfer Pricing Guidelines (Austrian Guidelines) 2021. The Austrian Guidelines 2021 are an essential interpretative aid for the application of the arm’s-length
See MoreSingapore releases updated Transfer Pricing Guidelines
On 10 August 2021, the Inland Revenue Authority of Singapore published the sixth edition of its E-Tax Guide on Transfer Pricing. The most important changes are summarized as follows: Additional guidance on cost contribution arrangements (CCAs)
See MoreOECD: Updates to Transfer Pricing Country Profiles
On 3 August 2021 the OECD issued an updated version of some of its transfer pricing country profiles, These include new country profiles for Angola, Romania and Tunisia, and updated profiles for seventeen other countries. The updated profiles have
See MoreGermany: MoF publishes new administrative principles on TP
On 14 July 2021, the Ministry of Finance (MoF) has issued new administrative principles on transfer pricing. The administrative principles include extensive references to the OECD Transfer Pricing Guidelines and provide further details clarifying
See MoreOECD: Exchange of Information commences under Global Standard on Substantial Activities
From 31 March 2021 twelve low tax jurisdictions have begun exchanging information under the global standard on substantial activities. The OECD’s Inclusive Framework aims to ensure through application of the global standard that substantial
See MorePlatform for Collaboration on Tax: Toolkit on Implementing Transfer Pricing Documentation Requirements
On 19 January 2021 the Platform for Collaboration on Tax (PCT) published the “Practical Toolkit to Support the Successful Implementation by Developing Countries of Effective Transfer Pricing Documentation Requirements”. The PCT was set up by
See MoreOECD: Implementation of transfer pricing for hard-to-value intangibles
On 16 December 2020 the OECD published information setting out the extent to which member countries of the Inclusive Framework have implemented the recommendations on hard to value intangibles (HTVI) drawn up as part of the OECD/G20 project on base
See MoreUK: Statistics on Transfer Pricing and Diverted Profits Tax
On 27 January 2020 HMRC published statistics relating to transfer pricing and the diverted profits tax. HMRC had 441 full time equivalent staff working on international tax issues involving multinational groups in 2018/19, including transfer
See MoreSaudi Arabia: GAZT holds seminar to simplify the transfer pricing regulations
On 17 June 2019, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia has organized a transfer pricing seminar in Riyadh to simplify the key areas of the transfer pricing (TP) regulations published on 15 February 2019 and to address
See MoreSingapore: IRS Publishes TP guidelines for commodity marketing and trading activities
On 24 May 2019, the Inland Revenue Service of Singapore (IRS) has published a new transfer pricing (TP) E-Tax guide aimed at helping taxpayers compute the economic value of commodity marketing and trading activities conducted by related parties.
See MoreOECD: Discussion Draft on Transfer Pricing for Financial Transactions
On 3 July 2018 the OECD released a discussion draft on financial transactions in relation to BEPS actions 8 to 10 (ensuring that transfer pricing outcomes are in line with value creation). This has been issued as part of the follow-up work on the
See MoreSweden: Tax Authority publishes guidelines on use of CbC report information
On 18 May 2018, the Swedish tax authority issued guidelines, clarifying its use of country-by-country (CbC) report information. The guidelines are in line with the OECD guidelines on the appropriate use of information included in CbC reports that
See MoreEl Salvador issues new Transfer Pricing Guidelines
On 21 March 2018, the General Directorate of Internal Taxes of the Ministry of Finance issued the Transfer Pricing Orientation Guide (DG-001/2018). These guideline is intended to help taxpayers to comply with the following legal obligations: The
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