Italy: Draft transfer pricing regulations and corresponding adjustments
On February 21, 2018 the Italian Ministry of Economy and Finance released its draft transfer pricing rules to comply with the Article 8-10 OECD/G20 Base Erosion and Profit Shifting (BEPS) project. The draft rules are declared in their website for
See MoreOECD: Project to examine differences between Brazil’s transfer pricing rules and the Guidelines
On 28 February 2018 the OECD and Brazil began a joint project to examine the similarities and gaps in approaches to valuation of cross-border transactions. The project aims to produce an assessment of possibilities to bring the transfer pricing
See MoreNew Zealand: A tax bill to counter tax avoidance introduces into Parliament
On 6 December 2017, a tax bill to counter tax avoidance has been introduced into New Zealand’s Parliament by multinational companies and Minister of Revenue also published its commentary on the bill. Most provisions would enter into effect July
See MoreTaiwan: MOF publishes draft amendment to transfer pricing guidelines
The Tax Administration of the Ministry of Finance (MOF) has published a draft amendment to the transfer pricing guidelines for public consultation on 27th July 2017. According to the draft regulations, the Master File should include an overview of
See MoreVietnam publishes guidance on new transfer pricing requirements
The Ministry of Finance on 22 June 2017 published Circular 41/2017 / TT-BTC (28 April 2017), which provides some guidelines for the application of Decree No 20/2017 and this Circular will take effect on 1 May 2017. Circular 41/2017 introduced some
See MoreOECD: Revised guidance on profit splits
A discussion draft issued by the OECD on 22 June 2017 contains revised guidance on profit splits. This guidance is issued in relation to the clarification and strengthening of the guidance on the transactional profit split method as outlined in the
See MoreSweden approves the new legislation on transfer pricing documentation and CbC reporting
Sweden's parliament on 1 March 2017, adopted the government’s proposal on transfer pricing documentation and country-by-country reporting. The adoption amounts to the ratification of OECD’s guidelines for transfer pricing documentation and
See MoreBulgaria: Transfer pricing regulations
Bulgaria fully follows and applies the OECD Transfer Pricing (TP) guidelines and has had robust TP rules for several years, but taxpayers must be concerned about the regulations. The TP rules were first announced in the Corporate Income Tax Act
See MoreSweden: Transfer pricing guidance updated with BEPS
The tax authorities issued an updated version of the Swedish Transfer Pricing guidance on July 2, 2016. The guidance has been updated with the final report on aligning Transfer Pricing outcomes with value creation (Actions 8-10) of the Action Plan
See MoreOECD: Conforming amendments to guidelines on business restructurings
On 4 July 2016 the OECD published a document for public review containing the conforming amendments to Chapter IX of the OECD Guidelines (business restructurings) following the changes made to other parts of the Guidelines as a result of the final
See MoreAustria: Publishes Transfer Pricing Documentation draft Law
The Austrian Ministry of Finance (MoF) published the draft of the European Union (EU) Tax Amendment Act 2016 on 9 May 2016. The focus of this proposal is the draft of the new Austrian Transfer Pricing Documentation Law (TPDL). The new law serves as
See MoreDenmark: Publishes new transfer pricing documentation guidelines
The Danish Ministry of Taxation issued two Orders : BEK nos. 401 and 402, on 28 April 2016, concerning transfer pricing documentation. The new documentation guidelines BEK no. 402, which will replace the previous guidelines of 24 January 2006 (BEK
See MoreEU Joint Transfer Pricing Forum meeting in February 2016
The next meeting of the EU Joint Transfer Pricing Forum (EU JTPF) is scheduled for 18 February 2016. The EU JTPF aims to provide tools for practical application of transfer pricing rules in the EU and ensure efficient transfer pricing
See MoreSingapore: Changes to Transfer Pricing Guidelines
The Inland Revenue Authority of Singapore (IRAS) published the third edition of the e-Tax Guide on the transfer pricing guidelines on 4 January 2016. The latest changes are summarized as follows: Amended guidance on the cost-plus method (CPM);
See MoreOECD holds public consultation on transfer pricing issues
On 19 and 20 March 2015 the OECD held a public consultation on transfer pricing matters arising from the action plan on base erosion and profit shifting. The first day of the conference dealt with the draft amendments and additions to Chapter 1 of
See MoreOECD publishes comments received on transfer pricing aspects of commodity transactions
The OECD has published on its website comments received on the discussion draft on the transfer pricing aspects of cross border commodity transactions. This was issued as part of the response to action 10 of the base erosion and profit shifting
See MoreIndia: Amendments to Transfer Pricing Guidelines Issued
The Central Board of Direct Taxes released amendments to the transfer pricing guidelines on 4 February 2015. The “simplified” transfer pricing documentation rules were released by a notification dated 4 February 2015 for domestic transactions of
See MoreEU: sets up new mandate for the Joint Transfer Pricing Forum
As the previous mandate for the EU Joint Transfer pricing Forum had expired, on 26 January 2015 the European Commission issued Commission Decision C (2015) 247 in respect of setting up a new EU Joint Transfer Pricing Forum expert group. The previous
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