Korea: Update on rules for application of arm’s length standard to head office–branch transactions
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
See MorePoland – Changes to transfer pricing documentation, thin capitalization rules
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
See MoreIndia: General Anti-Avoidance Rule For 2014
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
See MoreImplementation of Malaysian thin capitalization has been deferred
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
See MoreIndonesia – Potential changes to the transfer pricing regulations
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
See MoreAustralia – Proposed amendments of transfer pricing rules
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
See MoreBrazil Provisional Measure 6272013 – CFC rules for resident individuals introduced
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
See MoreUK Budget Delivers Tax Cuts
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
See MoreRussia- Introduces new Transfer Pricing Rules
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
See MoreNew CFC Rules Released in UK
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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