Canada: 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 MoreAzerbaijan: The Ministry of Taxes and the IFC are Working to Protect Withdrawal of Profits from Taxation
The Ministry of Taxes of Azerbaijan and the International Finance Corporation (IFC) are working on a draft agreement on transfer pricing. The aim is to protect withdrawal of profits from Taxation. Azerbaijan will be able to go to the international
See MoreTaiwan: Proposed Amendments to Transfer Pricing Rules
The Ministry of Finance of Taiwan has proposed changes to the transfer pricing rules (Tai Cai Shui No. 10304651710). The draft of amendments was released on 7 January 2015 for public comment. The modifications, which concern one new provision and
See MoreLuxembourg: Formalization of New Transfer Pricing Legislation and Documentation Requirements
The Parliament of Luxembourg has approved the draft law and has formalized the framework for Luxembourg transfer pricing legislation and introduced the transfer pricing documentation requirements. The new measures are effective from 1 January
See MoreSpain: Modifies the transfer pricing legislation
In the “Corporate Income Tax Reform 2015” enacted under the Law 27/2014 the following transfer pricing rules are amended; Scope of related-party transactions - The ownership requirement for related parties is increased from 5% (1% in the
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 MoreHungary: Presents tax laws for 2015
The tax laws for 2015 were presented to the parliament by the government on 28 October 2014. According to the tax laws, some changes for 2015, would include in the definition of related parties an additional provision relating to entities where
See MoreSlovak Republic: Tax amendments for 2015 has approved by the Parliament
The Parliament of Slovak Republic has approved the proposed changes regarding the Income Tax Act on 30th October 2014 and it is to be in effect from 1st January 2015. The amendments are basically held on thin capitalization rules, local transfer
See MoreSpain: Releases modified tax laws by the Spanish Government
On 23 June 2014, draft bills modifying the most important Spanish tax laws were released. The Spanish Government released the second draft bill on 1 August 2014, which will now be discussed and voted on by the Spanish Parliament. It is intended that
See MoreCzech Republic: Obligatory reporting on related-party transactions
The Czech Tax Administration has declared a new reporting obligation for all entities accountable for corporate income tax in the Czech Republic who has dealings with related parties. Czech taxpayers will have to file a separate disclosure form
See MoreIndia: Introduces new rules aim to reduce transfer pricing tax disputes
The government of India introduced new tax rules with their new budget target to reducing litigation with multinational firms over cross-border transactions the government considers tax avoidance schemes. Now days, transfer pricing is an application
See MoreSlovak Republic: New improvements in Transfer Pricing
The Financial Directorate in Slovak Republic has issued a methodological guideline on the application of transfer pricing methods. According to the changes to the OECD Transfer Pricing Guidelines in July 2010, the amendment to the ITA has abolished
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 MoreAngola introduced transfer pricing rules
Angola introduced a transfer pricing rule with a Presidential Decree n. 14713 on June 2014. According to the decree, the taxpayers require to submit transfer pricing documentation by the end of June 2014 to the tax management for the 2013 tax year.
See MoreMexico – Transfer pricing implications of pro-rata expense decision
A recent decision from Mexico’s Supreme Court of Justice declared a provision of the tax law to be unconstitutional. The provision related to pro-rata expenses incurred abroad relating to natural or legal persons that are not Mexican taxpayers.
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 MoreAustralia: Draft ATO guidance on new transfer pricing rules
New draft tax Rulings and draft Practice Statements outline the Australian Tax Office’s approach to transfer pricing and the standards that are required from taxpayers. Businesses need to urgently consider these publications in order to manage tax
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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