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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Russia–Readjusting the taxable base for transfer pricing purposes may impact on the VAT base

December 10, 2013

The Russian Ministry of Finance has made public Letter No. 03-01-18/19214 clarifying the rights of tax authorities to readjust the taxable base in the case of selling goods and performing of works or services between related parties. Article 105.3

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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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Chile: Circular notifying transfer pricing changes

July 25, 2013

The Chilean Internal Revenue Service (IRS) has released Circular No. 29 on June 14, 2013 that includes instructions regarding the new transfer pricing rules introduced by Law 20,630. The circular recognizes the OECD TP Guidelines as a valid source

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India: Requirements For Transfer pricing’s “deemed international transaction”

May 22, 2013

India’s transfer pricing rules are designed to prevent the use of transfer prices between related enterprises to shift profits away from India to a lower tax jurisdiction. The rules are therefore generally concerned with international transactions

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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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Indonesia – Potential changes to the transfer pricing regulations

December 10, 2012

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

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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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Russia- Introduces new Transfer Pricing Rules

February 12, 2012

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

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