India: No related-party relationship, despite substantial single-party purchases
In the case of: DCIT v. W.B. Engineers International Pvt. Ltd. (ITA No. 523/PN/2014, The Pune Bench of the Income-tax Appellate Tribunal upheld the findings of the Dispute Resolution Panel that because a taxpayer merely hold substantial
See MoreAustralian Taxation Office releases GAAR guidelines
The Australian Taxation Office released for comment a draft practice statement PS LA 2005/24 which deals with the application of the general anti-avoidance rules (GAAR) in Part-IVA of the Income Tax Assessment Act 1936 on 13 August 2015. This Draft
See MoreCosta Rica Introduces arm’s length price principle
The Bill No. 19,679 dated 12 August 2015 was submitted to the Legislative Assembly to introduce the arm's length principle to further develop the transfer pricing rules via regulations. The Bill No. 19,679 dated 12 August 2015 was submitted to the
See MoreChile: IRS issues guidelines regarding anti-avoidance rules
The Inland Revenue Service (IRS) in Chile has issued total 7 circulars including Circulars 65 and 68 on 23rd July 2015 for giving directions won the anti-avoidance rules enacted as part of Law No. 20780. The circulars contain limitations on the
See MoreChile: Bill to amend the tax reform of 2014
The Finance Ministry has declared that the Government submitted a bill on 10th August 2015 to amend the tax reform of 2014. The main features of the bill will be as follows: The combined income tax regime with income attribution would be
See MoreRussia: Federal Council accepts amendments on CFC rules
The Russian Federation Council has accepted draft law, No. 714002-6 on 3rd June 2015 that contains changes to the Controlled Foreign Company (CFC) rules and the tax residency idea. It was signed by the President and officially published on 8th June
See MoreIceland Modifies Transfer Pricing Rules
Iceland's Parliament has approved a Bill on 15 June 2015 amending article 57 of the Icelandic Income Tax Act No. 90/2003 setting out transfer pricing rules. According to the Bill entities with turnover or total assets exceeding ISK 1 billion need
See MoreChile: Circular 30 regarding administrative interpretation published
A Circular 30 of the tax administration (Servicio de Impuestos Internos, SII) about SII's administrative interpretation concerning amendments introduced by Law 20,780 to the Income Tax Law and specifically, it contains the new article 41 G on CFC
See MorePoland: New thin capitalization rules
The thin capitalization rules changes in Poland and this rule enacted as an amendment to Poland’s corporate income tax law, and signed by the president on 17 September 2014 and from 1 January 2015 the “thin capitalization” rules has been
See MoreRussia: Law concerning notification process of CFCs adopted
The parliament has approved Law No. 667946-6 on 27th March 2015 for extending the deadline of tax resident’s notification about the involvements held in controlled foreign companies (CFCs). The deadline for notification has been extended from 1st
See MoreRussia: State Duma considers new draft law regarding thin capitalization rules
The Russian State Duma Council accepted the decision on 17th February 2015 to incorporate a new draft of Law No. 724609-6 on the introduction of changes to Article 269, Part 2 of the Tax Code regarding the meaning of controlled debt. The draft law
See MoreTaiwan: Amendments to Transfer Pricing Rules
The Ministry of Finance announced on 6 March 2015 amendments to the transfer pricing rules governing non-arm’s length transactions of profit-seeking enterprises. This amendment coming 10 years after the promulgation of the transfer pricing
See MoreRussia: State Duma passes new tax law without extension of thin capitalization rules
The President has signed a new law on 8th March 2015 for changing article 269 of the Russian Tax Code. Precisely, the provisions of extending thin capitalization rules to foreign affiliates and bank loans are excluded from the new law. Under Russian
See MoreJapan: Tax Reform Plan 2015 Submitted to the Diet
The bills for the proposed changes to the tax law as announced on 30 December 2014 were submitted to the Diet on 17 February 2015. The main Proposal for changes is summarized below: Corporation taxation: The corporate tax rate is reduced for
See MoreRussia: Amendments to transfer pricing rules have entered into force
On the basis of Federal Law No. 379-FZ, the amendments has made in transfer pricing (TP) rules and it was issued on 29th November 2014. This amendments to TP rules have entered into force on 1st January 2015. The important changes are given
See MoreRussia: 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
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