US: IRS Released Temporary Regulations to Clarify that the Arm’s-Length Standard of Section 482 Applies to all Controlled Transactions

October 01, 2015

IRS issued Treasury Decision 9738 on 14 September 2015 containing temporary regulations under Section 482 clarifying the application of the arm’s-length standard when multiple code sections. The temporary regulations apply to tax years ending on

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Costa Rica Introduces arm’s length price principle

August 15, 2015

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

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Canada: New Transfer Pricing Memorandum (TPM-16) published

February 23, 2015

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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Greece Defines “Related Persons” for Transfer Pricing Purposes

January 14, 2015

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

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Tanzania: regulations on transfer pricing released

July 08, 2014

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

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OECD official suggests alternatives to arm’s length standard may be needed

April 27, 2014

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

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Saudi Arabia issues new Ministerial Resolution amending tax by-laws

April 27, 2014

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

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Russia Clarifies transfer pricing for Domestic Transactions

March 31, 2014

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

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Iceland enacted its own transfer pricing legislation

March 09, 2014

Iceland has recently enacted its own transfer pricing legislation, which became effective from January 1, 2014. The transfer pricing rules are now regulated by Article 57 of Act No. 90/2003 on Income Tax based on the arm's length standard. There

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Russia: Ministry of Finance clarifies the transfer pricing rules

February 17, 2014

The Ministry of Finance Letter No. 03-01-18/53941, issued on 10 December 2013, clarifies the rules to determine the income for controlled transactions purposes. The Ministry of Finance specified that transactions defined in article 105.14 of the Tax

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India – Arm’s length price for sourcing support services

December 26, 2013

The Delhi High Court has held that the Transfer Pricing Officer’s determination of an arm’s length price based on a 5% markup of the “free on board” (FOB) value of goods sourced for a related party’s contract with third parties was

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India: Determines guarantee rates on loans are arm’s length

December 12, 2013

The Mumbai Bench of the Income-tax Appellate Tribunal held that bank guarantee rates cannot be mechanically applied in determining the arm’s length price. The tribunal explained the difference between corporate guarantee and bank guarantee, and

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India: Determines arm’s length price of share transfers

December 10, 2013

The Income-tax Appellate Tribunal has held that the discounted cash flow method was preferable over the “yield” method or “net asset value” method for purposes of determining the arm’s length price of shares transferred to related parties.

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Brazil: Changes to transfer pricing regulations

October 22, 2013

Brazil issued Normative Instruction 1,395/2013 on 30 September 2013.This Instruction introduced changes to Normative Instruction 1,312/2012 regarding the prices that must be used in cross-border transactions involving the sale and purchase of goods,

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Korea: Update on rules for application of arm’s length standard to head office–branch transactions

April 01, 2013

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

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Australia – Proposed amendments of transfer pricing rules

December 10, 2012

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

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