UK: Terms of Reference issued for GAAR advisory panel

June 04, 2013

The legislation in respect of the General Anti Abuse Rule (GAAR) in the Finance Bill 2013 provides for the appointment of a GAAR advisory panel. The panel is to consider and approve HMRC’s guidance on the GAAR. It is also required to consider

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India: Requirements For Transfer pricing’s “deemed international transaction”

May 22, 2013

India’s transfer pricing rules are designed to prevent the use of transfer prices between related enterprises to shift profits away from India to a lower tax jurisdiction. The rules are therefore generally concerned with international transactions

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Australia: Proposal to amend GAAR

May 16, 2013

The Australian government on 13th February 2013 introduced Tax Laws Amendment Bill 2013. According to Tax Laws Amendment Bill 2013, companies will have to ensure that the commercial and other factors motivating a decision are properly documented.

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Korea: Update on rules for application of arm’s length standard to head office–branch transactions

April 01, 2013

Korea’s Ministry of Strategy and Finance has issued new regulations to clarify the method for calculating domestic-source income from intra-company transactions between a foreign head office and its Korean branch. This follows the passing of the

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Poland – Changes to transfer pricing documentation, thin capitalization rules

March 05, 2013

Legislation to expand the scope of Poland’s corporate income tax law is intended to be effective in 2014. The provisions of the legislation released on February 18, 2013 include changes to the transfer pricing documentation and thin capitalization

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India: General Anti-Avoidance Rule For 2014

February 24, 2013

The General Anti –Avoidance Rule (GAAR) of India had been scheduled to be implemented from April 2014. After further consultation the provisions will however now come into effect from April 1, 2016 and these provisions would be used to target only

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Implementation of Malaysian thin capitalization has been deferred

December 23, 2012

The Ministry of Finance announced on 11 December 2012 that the implementation of the thin capitalization rules has been deferred until the end of December

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Indonesia – Potential changes to the transfer pricing regulations

December 10, 2012

The Director General of Taxation of Indonesia has recently focused on transfer pricing, proposing some changes to the existing transfer pricing rules. However, these proposals are not yet final and some changes may be made before the final issuance

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Australia – Proposed amendments of transfer pricing rules

December 10, 2012

The Australian Assistant Treasurer has recently  Tax Laws Amendment (Cross-Border Transfer Pricing) Bill 2013: Modernization of transfer pricing rules,in which changes to transfer pricing rules were proposed. The new law focuses mainly on

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Brazil Provisional Measure 6272013 – CFC rules for resident individuals introduced

December 04, 2012

On 4 December 2013 it has been published that the Provisional Measure 627/2013 (PM 627/2013), introduced important changes to the Brazilian tax legislation. This was published in the Official Gazette of 12 November 2013. Among those changes, PM

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UK Budget Delivers Tax Cuts

March 23, 2012

The UK has delivered a Budget that unashamedly backs businesses, slashing the top rate of personal income tax and accelerating corporate tax cuts. Currently charged at 50% on all income over GBP150, 000, from April, 2013 the rate will drop to

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Russia- Introduces new Transfer Pricing Rules

February 12, 2012

New Federal Law FZ-227 of 18 July 2011 which enacted comprehensive transfer pricing rules entered into force on 1 January 2012. According to the new Law, companies falling under the scope of transfer pricing rules will be obligated to disclose

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New CFC Rules Released in UK

July 04, 2011

The UK government has published its proposals for the reform of the Controlled Foreign Company (CFC) regime through a press release on 4 July 2011. The government intends to modernize the CFC regime in 2012, which it expects will better reflect the

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