Mozambique: Council of Ministers approves first transfer pricing regulations
On December 6, 2017, the Council of Ministers has approved the first Transfer Pricing (TP) Regulations by Decree 70/2017. The Decree became in force on or after the January 1, 2018. According to Decree, one company is considered to be related to
See MoreUkraine: Parliament adopts the amendment to the Tax Code
On 7 December 2017, the Ukrainian Parliament passed the Law of Ukraine "On Amendments to the Tax Code of Ukraine and Certain Laws of Ukraine on Securing Balance of Budget Revenues in 2018” No. 2245-VIII (“Law”). The law came into force on 1
See MoreNew Zealand: A tax bill to counter tax avoidance introduces into Parliament
On 6 December 2017, a tax bill to counter tax avoidance has been introduced into New Zealand’s Parliament by multinational companies and Minister of Revenue also published its commentary on the bill. Most provisions would enter into effect July
See MoreZambia: Budget for 2018
Finance Minister of Zambia presented the 2018 National Budget for the year 1 January 2018 to 31 December 2018 to the National Assembly on 29th September 2017. Budget for 2018, which lays out the various expenditure and revenue measures aimed at
See MoreMozambique: Transfer pricing regulations approved
The Council of Ministers approved transfer pricing regulations on September 12, 2017 that present the methods for the assessment of the transfer pricing transactions between related entities. It allows amendments to the taxable profit by the tax
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 MoreThailand: Consultation process of the draft Transfer Pricing rules
The Revenue Department of Thailand is requesting public comments with respect to the Draft Transfer Pricing Rules which were approved by the Thai Cabinet on May 2015. The comments are to be provided by 7 July 2017. Recently, the draft measures were
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 MoreVietnam: Recently released a new transfer pricing decree
Vietnam’s Government has recently released a Transfer Pricing (“TP”) Decree No. 20/2017/ND-CP on 24 February 2017, provided that tax administration applicable to enterprises having controlled transactions’ (Decree 20), which will take effect
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 MoreIndia: Related-party Relationship Upheld by The Tribunal
Recently, the Chennai Bench of the Income-tax Appellate Tribunal (the Tribunal) in the case of: Hospira Healthcare India Private Limited v. DCIT (ITA No. 821/Mds/2016 - AY 2011-12), held that under a provision of India’s tax law, “influence”
See MoreIndia: Proposes amendments to the transfer pricing regulations
Indian Finance Minister published India’s 2017-18 budget on 1 February 2017. Along with other measures, the budget has proposed following important amendments to the provisions of transfer pricing (TP) regulations of India: –A major proposal in
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 MoreSlovenia: Publishes advance pricing agreement rules
Details on the introduction of Advance Pricing Arrangements (APAs) are now available in the Official Gazette on 28 December 2016. Accordingly, the following rules will apply from January 2017: (i) The application of APA must be addressed to the
See MoreDenmark: Issues CbC notification rules
The Danish tax authorities (SKAT) on 9 December 2016 announced that country-by-country (CbC) notifications must be submitted electronically and in a standardised format on Form 05.034. The form contains instructions both in English and Danish, and
See MoreBulgaria: Transfer pricing regulations
Bulgaria fully follows and applies the OECD Transfer Pricing (TP) guidelines and has had robust TP rules for several years, but taxpayers must be concerned about the regulations. The TP rules were first announced in the Corporate Income Tax Act
See MoreVietnam: Publishes the draft decree on transfer pricing
The final draft transfer pricing (TP) decree was released on 3 October 2016 by the Ministry of Finance, following Resolution No. 19-2016/NQ-CP dated 28 April 2016. The decree aims to replace the existing TP regulations, Circular 66/2010/TT-BTC, and
See MoreTurkey: Amendment in transfer pricing legislation
The Law No. 6728 on the amendment of certain laws for the improvement of the investment landscape has been published in the Official Gazette on 9 August 2016. This law amended certain transfer pricing provisions. Some of the provisions are given
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