US: 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 MorePolish parliament approves new transfer pricing rules
The parliament approved a bill on 11 September 2015 including changes the transfer pricing rules regarding transactions between related parties. According to the bill a taxpayer that is part of a multinational corporate group with annual income or
See MoreIndia: No related-party relationship, despite substantial single-party purchases
In the case of: DCIT v. W.B. Engineers International Pvt. Ltd. (ITA No. 523/PN/2014, The Pune Bench of the Income-tax Appellate Tribunal upheld the findings of the Dispute Resolution Panel that because a taxpayer merely hold substantial
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 MoreIceland Modifies Transfer Pricing Rules
Iceland's Parliament has approved a Bill on 15 June 2015 amending article 57 of the Icelandic Income Tax Act No. 90/2003 setting out transfer pricing rules. According to the Bill entities with turnover or total assets exceeding ISK 1 billion need
See MoreTaiwan: Amendments to Transfer Pricing Rules
The Ministry of Finance announced on 6 March 2015 amendments to the transfer pricing rules governing non-arm’s length transactions of profit-seeking enterprises. This amendment coming 10 years after the promulgation of the transfer pricing
See MoreRussia: Amendments to transfer pricing rules have entered into force
On the basis of Federal Law No. 379-FZ, the amendments has made in transfer pricing (TP) rules and it was issued on 29th November 2014. This amendments to TP rules have entered into force on 1st January 2015. The important changes are given
See MoreRussia: Guidance on definition of related parties
The Finance Ministry (MoF) has issued Letter No. 03-01-18/1989 on 23rd January 2015 describing the rules for definition of a company and its employees as related parties for transfer pricing determinations. The MoF considered that the meaning of
See MoreNigeria: Stock exchange rules regarding related-party transactions
The Nigerian Stock Exchange has issued rules for lending transactions with related parties or interested persons to guard against the risk that interested persons could influence an issuer, its affiliates or associated companies. One provision is
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 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
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