Russia: Guidance on definition of related parties
The Finance Ministry (MoF) has issued Letter No. 03-01-18/1989 on 23rd January 2015 describing the rules for definition of a company and its employees as related parties for transfer pricing determinations. The MoF considered that the meaning of
See MoreNigeria: Stock exchange rules regarding related-party transactions
The Nigerian Stock Exchange has issued rules for lending transactions with related parties or interested persons to guard against the risk that interested persons could influence an issuer, its affiliates or associated companies. One provision is
See MoreCanada: New Transfer Pricing Memorandum (TPM-16) published
The Canada Revenue Agency (CRA) has published new Transfer Pricing Memorandum (TPM-16) on 23rd February 2015 that reconfirms the CRA’s existing positions and gives proper instruction on the use of multiple-year data in determining an
See MoreChile: Changes to Thin Capitalization rules
The Circular 12 regarding amendments to the thin capitalization rules introduced by Law 20,780 of the tax administration has released in the Official Gazette of 5th February 2015. From 1st January 2015, thin capitalization rules are directed by
See MoreAzerbaijan: The Ministry of Taxes and the IFC are Working to Protect Withdrawal of Profits from Taxation
The Ministry of Taxes of Azerbaijan and the International Finance Corporation (IFC) are working on a draft agreement on transfer pricing. The aim is to protect withdrawal of profits from Taxation. Azerbaijan will be able to go to the international
See MoreRussia: Clarifications on computing taxable income of CFCs published
The Ministry of Finance (MoF) has released Letter No. 03-03-06/1/68300 describing the process to calculate the taxable income of controlled foreign companies (CFCs) for the purposes of taxation in Russia. The letter was issued on 29th December 2014.
See MoreTaiwan: Proposed Amendments to Transfer Pricing Rules
The Ministry of Finance of Taiwan has proposed changes to the transfer pricing rules (Tai Cai Shui No. 10304651710). The draft of amendments was released on 7 January 2015 for public comment. The modifications, which concern one new provision and
See MoreLuxembourg: Formalization of New Transfer Pricing Legislation and Documentation Requirements
The Parliament of Luxembourg has approved the draft law and has formalized the framework for Luxembourg transfer pricing legislation and introduced the transfer pricing documentation requirements. The new measures are effective from 1 January
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 MoreRussia: Draft law on the thin capitalization rule submitted to State Duma
The Draft Law No. 675906-6 regarding the introduction of changes to article 269 of part 2 of the Tax Code in respect to the meaning of the concept of controlled indebtedness has been submitted to the State Duma on 16th December 2014. A
See MoreSpain: Modifies the transfer pricing legislation
In the “Corporate Income Tax Reform 2015” enacted under the Law 27/2014 the following transfer pricing rules are amended; Scope of related-party transactions - The ownership requirement for related parties is increased from 5% (1% in the
See MoreGreece Defines “Related Persons” for Transfer Pricing Purposes
The Public Revenue Administration issued a letter ruling on 9 January 2015 to define a “related person” for transfer pricing purposes. As per the Ruling letter, a related person is who owns at least 33% of equity shares or voting rights and
See MoreChina: SAT Regulates the Administration of the GAAR
Recently, the State Administration of Taxation (SAT) issued the Administrative Measures on the General Anti-Avoidance Rule (GAAR) to further regulate and clarify various matters, such as applicable scope, judging criteria, adjustment methods,
See MoreRussia: Taxation of Controlled Foreign Companies and other anti-offshore measures
The amendments to the Tax Code on CFC, has focused on the following matters: Controlled foreign companies Beneficial ownership Tax residence determination by the company's management place Taxation of real estate transactions Criminal
See MoreRussia: Law providing CFC rules signed
The President of Russia has signed a Federal Law No. 376-FZ for introducing the CFC rules on 24th November 2014. The law enters into force with effect from 1st January
See MoreRussia: CFC law has been adopted by the Federal Council
The Federal Council has adopted the draft law on 19th November 2014 that initiates the CFC rules. There is no significant change in the adopted law compared to the previous draft. This law will enter into force with effect from 1st January
See MoreHungary: Presents tax laws for 2015
The tax laws for 2015 were presented to the parliament by the government on 28 October 2014. According to the tax laws, some changes for 2015, would include in the definition of related parties an additional provision relating to entities where
See MoreRussian Parliament to Consider Revised Draft of CFC Law
On 22 October 2014 the Russian parliament received a new version of the draft law on controlled foreign companies (CFCs). Parliamentary hearings on the latest draft law are to take place on 11 November 2014. Generally the draft law aims to
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