South Africa introduces Budget 2019 in parliament
On 20 February 2019, Tito Mboweni (South Africa’s Minister of Finance) presented the Budget 2019 in the parliament. The budget proposal would not increase taxes in any category but proposed to increase tax collection by not adjusting for inflation
See MoreJapan proposes tax reform plans for 2019
On 14 December 2018, Japan's ruling coalition party has approved a package of tax reform proposals for 2019. The proposal includes amendments to Japan’s controlled foreign company (CFC), interest expense limitation, and general transfer pricing
See MoreIreland announces corporation tax roadmap
On 5 September 2018, the Minister for Finance and Public Expenditure & Reform, Paschal Donohoe T.D., has published Ireland’s Corporation Tax Roadmap. The Roadmap takes stock of the changing international tax environment, outlines the actions
See MoreRussia modifies transfer pricing rules
On 3 August 2018, the President of the Russian Federation signed Law No. 302-FZ About changes to Part One and Two of the Tax Code of the Russian Federation" Once the new law enters into force, only transactions between Russian companies that apply
See MoreUK: Statistics on transfer pricing and diverted profits tax
On 1 August 2018 HMRC released a document showing the latest statistics relating to transfer pricing and the diverted profits tax (DPT). The transfer pricing rules and the DPT are seen by HMRC as an important part of the range of measures in place
See MorePoland releases draft law amending transfer pricing rules
On 16th July 2018, Poland has released a bill to amend the country's transfer pricing rules in line with the results of the BEPS project and the OECD transfer pricing guidelines 2017 in order to improve the taxation of large multinational companies.
See MoreMexico: The tax authority issues new rules regarding transfer pricing adjustments
On July 11, 2018 the Mexican Tax Authority (SAT) has published amendments to the rules for transfer pricing adjustments now included in rules 3.9.1.1-3.9.1.5 of Resolución Miscelánea Fiscal (RMF). These rules include the definition of transfer
See MoreAustralia: ATO publishes draft guidance on transfer pricing issues
The Australian Taxation Office (ATO) has issued Draft Schedule 2 to Practical Compliance Guideline (PCG) 2017/1 ATO compliance approach to transfer pricing issues related to centralized operating models involving procurement, marketing, sales and
See MorePakistan enacts Finance Bill 2018
The Finance Bill, 2018 was passed by the government on 22 May 2018, with some amendments. The Bill provides for the implementation of the measures proposed as part of the 2018-2019 Budget. The main measures are summarized as follows: Corporate
See MoreGermany: The CJEU decision permits deviations from the arm’s length principle
On 31 May 2018, the Court of Justice of the European Union (CJEU) issued its decision in the case of: C-382/16 Hornbach-Baumarkt that a parent company’s position as a shareholder of a non-resident company may be taken into account in
See MoreNetherlands publishes new transfer pricing decree
The Dutch Ministry of Finance published a new transfer pricing decree nr. 2018-6865 on 22 April 2018, which was published in the State Gazette on 11 May 2018. The Decree is in line with the outcomes of the Base Erosion and Profit Shifting (BEPS)
See MoreZambia: Government publishes new transfer pricing regulations
Zambia published the income tax (transfer pricing) (Amendment) regulations under Statutory Instrument No. 24 of 2018 in the official gazette on 6th April 2018. The 2018 regulations conduct transfer pricing transactions between related entities as
See MoreItaly: launches public consultation regarding implementation measures for transfer pricing provisions
The Italian Ministry of Economy and Finance launched a public consultation on the implementation measures associated with the application of domestic transfer pricing provisions on 21 February 2018. The main purpose of the Draft Decree (supported by
See MoreSingapore: 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 MoreNew Zealand: Government drafting amendments to transfer pricing rule
On 14th February 2018 government announced that it will recommend a change to transfer pricing provisions in a bill designed to lessen tax avoidance by multinationals. This bill concerns the new rule to limit the rate of deductible interest on
See MoreCroatia: Tax reforms effect from 1 January 2018
With effects from January 1, 2018, some tax law amendments have occurred in Croatia. These amendments contain tax laws, excise duties, reliefs etc.. The Minister of Finance issued the Ordinance on Amendments to the Ordinance on Profit Tax, which
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