Serbia: 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
See MoreChile: Government declares a bill to boost productivity
The Ministry of Finance declared on 6th May 2016 that the government had approved a bill to increase productivity. Tax measures contain: Expand the definition of export services to incorporate further services for VAT exemption upon
See MoreIndia: APA for earlier year may apply, determining “tested party”
Recently, the Delhi Bench of the Income-tax Appellate Tribunal (the Tribunal) in case of: Ranbaxy Laboratories Ltd. v. ACIT (ITA No. 196/Del/2013), held that overseas Associated Enterprises (AEs) being least complex entities in the transaction,
See MoreIndia: Bench marking the arm’s length interest rate on related-party debt
The Mumbai Bench of the Income-tax Appellate Tribunal held in the case of India Debt Management Pvt. Ltd. v. DCIT [IT(TP)A No. 7518/Mum/2014, held that the selection of tested party shall be done with reference to the entity which has undertaken
See MoreIndia: Factors to be used in selecting comparables
The Bangalore Bench of the Income-tax Appellate Tribunal recently provided judgment in the case of ACIT v. McAfee Software (India) Pvt Ltd, on factors such as functional comparability that are to be used in transfer pricing reports and
See MoreUK: Budget for 2016-2017 Updates Transfer Pricing Guidelines as Per Amended OECD Guidelines
The UK budget for 2016-17 includes an update of the transfer pricing guidelines in line with OECD Guidelines. This measure amends from 1 April 2016 the references within the relevant legislation to incorporate the most recent revisions to the OECD
See MoreIndia: Marketing & Sales Promotion Expenses Not International Transactions for Arm’s Length Standard
The Bangalore Bench of the Income-tax Appellate Tribunal held in the case of: Essilor India vt. Ltd. v. DCIT that advertising, marketing, and sales promotion expenses to promote brand value were incurred only for increasing the taxpayer’s sales,
See MoreSri Lanka: Tax proposals in National Budget 2016
The Finance Minister of Sri Lanka has presented the national budget 2016 on 20 November 2015. The Budget includes some changes related to the corporate income tax rate structure, several tax incentives for selected industries, the Economic Service
See MoreIndia Publishes Notification on Use of Arm’s Length Range and Multiple Year Data
Recently, the Central Board of Direct Taxes published 'Notification No. 83/2015' of 19 October 2015 revising the Income-tax Rules, 1962 in relation to the use of range and multiple year data. The Notification amends Rule 10B and introduces Rule
See MoreItaly: Published Legislative Decree on Transfer Pricing Issues in the Official Gazette
Italy Published Legislative decree n. 147 in the official gazette on 22 September 2015 with a view to provide investors with certainty arising from their investment plan. As per the published Legislative decree, expenses relating to the transactions
See More