Singapore: New transfer pricing rules
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
See MoreIndian APA accepts customs valuation as arm’s length price for transfer pricing
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
See MoreRussia: MoF clarification on application of thin capitalization rules in the context of tax treaties
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
See MoreIndia: Tribunal decision on foreign exchange fluctuation gain or loss and arm’s length pricing
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
See MoreItaly: Decree issued on urgent measures on tax matters
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
See MoreSerbia: Ministry of Finance publishes rulebook on arm’s length interest rates for 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
See MoreSingapore: IRS publishes Transfer pricing guidelines 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
See MoreIndia: Bench marking the arm’s length interest rate on related-party debt
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
See MoreUK: Budget for 2016-2017 Updates Transfer Pricing Guidelines as Per Amended OECD Guidelines
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
See MoreIndia: Marketing & Sales Promotion Expenses Not International Transactions for Arm’s Length Standard
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,
See MoreItaly: Published Legislative Decree on Transfer Pricing Issues in the Official Gazette
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
See MoreUS: IRS Released Temporary Regulations to Clarify that the Arm’s-Length Standard of Section 482 Applies to all Controlled Transactions
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
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 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 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 MoreTanzania: regulations on transfer pricing released
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
See MoreOECD official suggests alternatives to arm’s length standard may be needed
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
See MoreSaudi Arabia issues new Ministerial Resolution amending tax by-laws
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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