Czech Republic: Obligatory reporting on related-party transactions
The Czech Tax Administration has declared a new reporting obligation for all entities accountable for corporate income tax in the Czech Republic who has dealings with related parties. Czech taxpayers will have to file a separate disclosure form
See MoreRussia: Revised draft changes related to introduction of CFC rules
The Ministry of Finance has released a revised version of the draft law regarding introduction of CFC rules. The important changes of the revised draft law are given below: • Concepts regarding “Beneficial owner” and “actual right to receive
See MoreIndia: Introduces new rules aim to reduce transfer pricing tax disputes
The government of India introduced new tax rules with their new budget target to reducing litigation with multinational firms over cross-border transactions the government considers tax avoidance schemes. Now days, transfer pricing is an application
See MoreSlovak Republic: New improvements in Transfer Pricing
The Financial Directorate in Slovak Republic has issued a methodological guideline on the application of transfer pricing methods. According to the changes to the OECD Transfer Pricing Guidelines in July 2010, the amendment to the ITA has abolished
See MoreTanzania: regulations on transfer pricing released
The Transfer Pricing Regulations in Tanzania has finally been released through Government Notice No. 27 of 2014 and which is effective from 7 February 2014. The Income Tax Act 2004 already had a requirement in section 33 to transact between
See MorePoland: Proposals for CFC regime
Poland proposed bills to changes to its controlled foreign corporation (CFC) rules and thin capitalization regime. According to the rules tax would be levied on specific income which obtained from some foreign subsidiaries owned by the taxpayers of
See MoreRussia: Applicability of thin capitalization rules under certain conditions
The Ministry of Finance has issued Letter No. 03-08-05/9669 on May 6, 2014 that clarifies the application of thin capitalization rules to the interest paid by a Russian company (borrower) to another Russian company (lender) under a controlled loan
See MoreSlovak Republic: Thin capitalization rules has considered related-party debt
The Ministry of Finance is currently considering the chance of re-initiating thin capitalization rules into Slovak tax law. With the help of an internal document the Ministry of Finance highlights that low capitalization expresses an effective tax
See MoreAngola introduced transfer pricing rules
Angola introduced a transfer pricing rule with a Presidential Decree n. 14713 on June 2014. According to the decree, the taxpayers require to submit transfer pricing documentation by the end of June 2014 to the tax management for the 2013 tax year.
See MoreItaly: New anti-avoidance rules
The Italian Parliament approved the Law no. 23 of 2014 in March 2014 empowering the government to enact a partial reform of the Italian fiscal system. The government will adopt legislative decrees for the amendment of the Italian abuse of law and
See MoreNew Russian CFC and anti-avoidance legislation
The amended draft law regarding controlled foreign companies and other anti-offshore measures has done most valuable changes in the field of foreign tax structures and tax avoidance. This law has publicly available on 27 May, 2014. It highlights
See MoreMexico – Transfer pricing implications of pro-rata expense decision
A recent decision from Mexico’s Supreme Court of Justice declared a provision of the tax law to be unconstitutional. The provision related to pro-rata expenses incurred abroad relating to natural or legal persons that are not Mexican taxpayers.
See MoreColombia: issues regulations on thin capitalization provisions
The Colombian government issued Decree 627 on 26 March 2014. This Decree regulates the thin capitalization rules (article 118-1 of the Tax Code) that were brought in as part of the recent tax reforms and takes effect from the date of publication.
See MoreOECD official suggests alternatives to arm’s length standard may be needed
As part of the action plan on base erosion and profit shifting consideration is being given to ways to improve the transfer pricing rules. According to an official of the Organization for Economic Cooperation and Development (OECD), the arm’s
See MoreAustralia: Draft ATO guidance on new transfer pricing rules
New draft tax Rulings and draft Practice Statements outline the Australian Tax Office’s approach to transfer pricing and the standards that are required from taxpayers. Businesses need to urgently consider these publications in order to manage tax
See MoreSaudi Arabia issues new Ministerial Resolution amending tax by-laws
Saudi Arabia issued Ministerial Resolution No 1776 on 19 March 2014 to give effect to changes in some of the implementing regulations of the tax law. The resolution is effective from the date of issue and will apply to all tax cases including those
See MoreRussian Appeal Court rules on thin capitalization
Russia’s Arbitration Court of Appeal issued a decision on 24 February 2014 holding that a loan from a foreign related company of United Bakers Pskov LLC1 was subject to the thin capitalization legislation. This ruling by the Court was made on the
See MoreRussia Clarifies transfer pricing for Domestic Transactions
Letter No 03-01-18/2080 issued by the Russian Finance Ministry on 22 January 2014 clarifies that some domestic transactions are to be subject to the transfer pricing rules as they are deemed to be controlled transactions for this purpose. These
See More