Greece 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
See MoreCzech Republic: Obligatory reporting on related-party transactions
The Czech Tax Administration has declared a new reporting obligation for all entities accountable for corporate income tax in the Czech Republic who has dealings with related parties. Czech taxpayers will have to file a separate disclosure form
See MoreIndia: Introduces new rules aim to reduce transfer pricing tax disputes
The government of India introduced new tax rules with their new budget target to reducing litigation with multinational firms over cross-border transactions the government considers tax avoidance schemes. Now days, transfer pricing is an application
See MoreSlovak Republic: New improvements in Transfer Pricing
The Financial Directorate in Slovak Republic has issued a methodological guideline on the application of transfer pricing methods. According to the changes to the OECD Transfer Pricing Guidelines in July 2010, the amendment to the ITA has abolished
See MoreTanzania: regulations on transfer pricing released
The Transfer Pricing Regulations in Tanzania has finally been released through Government Notice No. 27 of 2014 and which is effective from 7 February 2014. The Income Tax Act 2004 already had a requirement in section 33 to transact between
See MoreAngola introduced transfer pricing rules
Angola introduced a transfer pricing rule with a Presidential Decree n. 14713 on June 2014. According to the decree, the taxpayers require to submit transfer pricing documentation by the end of June 2014 to the tax management for the 2013 tax year.
See MoreMexico – Transfer pricing implications of pro-rata expense decision
A recent decision from Mexico’s Supreme Court of Justice declared a provision of the tax law to be unconstitutional. The provision related to pro-rata expenses incurred abroad relating to natural or legal persons that are not Mexican taxpayers.
See MoreOECD official suggests alternatives to arm’s length standard may be needed
As part of the action plan on base erosion and profit shifting consideration is being given to ways to improve the transfer pricing rules. According to an official of the Organization for Economic Cooperation and Development (OECD), the arm’s
See MoreAustralia: Draft ATO guidance on new transfer pricing rules
New draft tax Rulings and draft Practice Statements outline the Australian Tax Office’s approach to transfer pricing and the standards that are required from taxpayers. Businesses need to urgently consider these publications in order to manage tax
See MoreSaudi Arabia issues new Ministerial Resolution amending tax by-laws
Saudi Arabia issued Ministerial Resolution No 1776 on 19 March 2014 to give effect to changes in some of the implementing regulations of the tax law. The resolution is effective from the date of issue and will apply to all tax cases including those
See MoreRussia Clarifies transfer pricing for Domestic Transactions
Letter No 03-01-18/2080 issued by the Russian Finance Ministry on 22 January 2014 clarifies that some domestic transactions are to be subject to the transfer pricing rules as they are deemed to be controlled transactions for this purpose. These
See MoreIsrael: Information regarding controlled transactions and documentation
According to the Art. 57 of Act 90/2003, parties are considered as related if they are part of a group under Art.2 Act 3/2006. The majority of shares is owned, directly or indirectly, by two or more legal entities within the group or they are
See MoreIceland enacted its own transfer pricing legislation
Iceland has recently enacted its own transfer pricing legislation, which became effective from January 1, 2014. The transfer pricing rules are now regulated by Article 57 of Act No. 90/2003 on Income Tax based on the arm's length standard. There
See MoreRussia: Ministry of Finance clarifies the transfer pricing rules
The Ministry of Finance Letter No. 03-01-18/53941, issued on 10 December 2013, clarifies the rules to determine the income for controlled transactions purposes. The Ministry of Finance specified that transactions defined in article 105.14 of the Tax
See MoreIndia – Arm’s length price for sourcing support services
The Delhi High Court has held that the Transfer Pricing Officer’s determination of an arm’s length price based on a 5% markup of the “free on board” (FOB) value of goods sourced for a related party’s contract with third parties was
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