France: Supreme Administrative Court makes a decision regarding TP disputes

January 15, 2021

Recently, the Supreme Administrative Court made a decision of a case “France vs Ferragamo France” against of Administrative Court. On 23 November 2020, the Administrative Court made a decision in this case in favour of Ferragamo and dismissed

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Poland: Council Ministers publishes draft bill amending CIT rules

September 28, 2020

On 16 September 2020, the Polish Council of Ministers published a draft bill amending the corporate income tax (CIT) rules to be in force from 1 January 2021. The bill includes the following tax measures; Limited partnerships in Poland are

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Serbia: Ministry of Finance publishes safe harbor interest rates for 2020

March 17, 2020

The Serbian ministry of finance has published the Rulebook on arm’s length interest rates that are applicable for 2020, which apply to interest rates on loans and credits between associated parties. The Rulebook was published in the Official

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OECD and Brazil: Report on project to align transfer pricing rules with OECD standards

July 18, 2019

On 7 July 2019 the OECD and Brazil’s tax administration (RFB) published a report on the results of the work programme launched in February 2018 to analyse Brazil's transfer pricing framework and the similarities and divergences between the

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Zambia: Tax Appeals Tribunals decision on arm’s length arrangements between related parties

April 10, 2019

Recently, the Tax Appeals Tribunal (TAT) issued a decision for the Zambia Revenue Authority (“ZRA”) in the case of: Nestlé Zambia Trading Limited v. Zambia Revenue Authority TAT 03, regarding transfer prices used with respect to its

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Germany: The CJEU decision permits deviations from the arm’s length principle

June 07, 2018

On 31 May 2018, the Court of Justice of the European Union (CJEU) issued its decision in the case of: C-382/16 Hornbach-Baumarkt that a parent company’s position as a shareholder of a non-resident company may be taken into account in

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Italy: launches public consultation regarding implementation measures for transfer pricing provisions

March 27, 2018

The Italian Ministry of Economy and Finance launched a public consultation on the implementation measures associated with the application of domestic transfer pricing provisions on 21 February 2018. The main purpose of the Draft Decree (supported by

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Singapore: New transfer pricing rules

March 27, 2018

Singapore Inland Revenue Authority published transfer pricing documentation rules and transfer pricing guidelines in February 2018. The major expansions of the transfer pricing rules are as follows: The arm’s length principle is aligned with

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Indian APA accepts customs valuation as arm’s length price for transfer pricing

March 23, 2018

Recently, the Central Board of Direct Taxes (CBDT) has entered into an advance pricing agreement (APA) where the price determined by the Indian Customs authorities was accepted as arm’s length price for import transactions for transfer pricing

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Russia: MoF clarification on application of thin capitalization rules in the context of tax treaties

February 25, 2018

Recently, the Ministry of Finance (MoF) issued a Guidance Letter (No. 03-03-06/1/87340) and clarified the application of domestic thin capitalization rules in the context of tax treaties. According to a statement by the MoF, interest paid by a

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India: Tribunal decision on foreign exchange fluctuation gain or loss and arm’s length pricing

August 10, 2017

The Income-tax Appellate Tribunal in the case of ACIT v. Rajratna Metal Industries Ltd. held that a foreign exchange fluctuation gain/loss is an operating item and is not to be excluded for the purpose of computing the arm’s length price

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Italy: Decree issued on urgent measures on tax matters

May 14, 2017

The Council of Ministers of Italy enacted a Law Decree No.50 with an effort to meet the European Union (EU) demands of extra budget deficit cuts. The Decree was published in the Official Gazette on 24 April 2017 and provides urgent measures on tax

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Serbia: Ministry of Finance publishes rulebook on arm’s length interest rates for 2017

March 19, 2017

The Serbian Ministry of Finance adopted the amendments to the Rulebook on arm's length interest rates (the Rulebook) on 10 March 2017. The rulebook contains the prescribed interest rates for taxpayers who had or will have related-party financing

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Singapore: IRS publishes Transfer pricing guidelines 2017

February 02, 2017

The Inland Revenue Authority of Singapore published the 4th version of transfer pricing guidelines on 12 January 2017, demonstrating compliance with international transfer pricing standards. The published guidelines explicitly refer to the Base

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India: Bench marking the arm’s length interest rate on related-party debt

April 18, 2016

The Mumbai Bench of the Income-tax Appellate Tribunal held in the case of India Debt Management Pvt. Ltd. v. DCIT [IT(TP)A No. 7518/Mum/2014,  held that the selection of tested party shall be done with reference to the entity which has undertaken

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UK: Budget for 2016-2017 Updates Transfer Pricing Guidelines as Per Amended OECD Guidelines

April 07, 2016

The UK budget for 2016-17 includes an update of the transfer pricing guidelines in line with OECD Guidelines. This measure amends from 1 April 2016 the references within the relevant legislation to incorporate the most recent revisions to the OECD

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India: Marketing & Sales Promotion Expenses Not International Transactions for Arm’s Length Standard

March 15, 2016

The Bangalore Bench of the Income-tax Appellate Tribunal held in the case of: Essilor India vt. Ltd. v. DCIT that advertising, marketing, and sales promotion expenses to promote brand value were incurred only for increasing the taxpayer’s sales,

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Italy: Published Legislative Decree on Transfer Pricing Issues in the Official Gazette

October 01, 2015

Italy Published Legislative decree n. 147 in the official gazette on 22 September 2015 with a view to provide investors with certainty arising from their investment plan. As per the published Legislative decree, expenses relating to the transactions

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