Russia: 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 MoreIndia: Finance Minister releases 2015 -2016 Budget
The Honorable Finance Minister of India on 28th February announced a budget aimed at high growth, saying the pace of cutting the fiscal deficit would slow as he seeks to boost investment and ensure that ordinary people benefit. Presenting the budget
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 MoreFinland: Proposal to amend the taxation of non-residents by assessment
Finnish Government proposes an amendment of the taxation for non-resident individual by assessment presenting a law proposal (HE365/2014) on 12 February 2015. The proposal entails that the taxation of non-resident individuals by assessment would be
See MoreChile: Changes to Thin Capitalization rules
The Circular 12 regarding amendments to the thin capitalization rules introduced by Law 20,780 of the tax administration has released in the Official Gazette of 5th February 2015. From 1st January 2015, thin capitalization rules are directed by
See MoreRussia: The MoF clarifies requirements to claim tax deduction of expenses
The Federal Tax Service has released Letter No. 03-03-10/4547 to clarify the requirements that must be completed by the primary accounting documents and it was issued by the Ministry of Finance (MoF). In accordance with the article 252 and article
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 MoreRomania: IMF issues preliminary report on economic situation
The IMF has issued a report stating their preliminary findings on the conclusion of a visit to Romania for discussions on the economic situation. The report notes that the Romanian economy has pursued sound economic policies and corrected internal
See MoreChina: SAT Standardizes the CIT Administration of Indirect Transfer of Taxable Properties in China by Non-Tax Resident Enterprises (Non-TREs)
Since the ‘Economic Reform and Opening up’, China has maintained an ongoing economic boom which has resulted in the accumulation of a considerable amount of wealth in the value of immovable properties, equity investments and other properties.
See MoreRussia: Clarifications on computing taxable income of CFCs published
The Ministry of Finance (MoF) has released Letter No. 03-03-06/1/68300 describing the process to calculate the taxable income of controlled foreign companies (CFCs) for the purposes of taxation in Russia. The letter was issued on 29th December 2014.
See MoreUK: Online Tax Summaries
More than 8 million taxpayers who filed their 2013 to 2014 tax return electronically by the 31 January deadline can now access their online tax summary. The summaries set out how much tax and National Insurance each person has paid in the tax year,
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 MoreTurkey: Draft order to change electronic tax filing
The tax administration has issued Draft Order No. 397 on 16th December 2014 regarding a public consultation on electronic tax filing. Taxpayers who want to register to communicate electronically with the tax authorities must have a suitable
See MoreDenmark: Filing a paper form is no longer possible for companies
The Ministry of Taxation announced, on 3 February 2015, a new schedule relating to the digitalization of corporate tax filing. A new schedule was required as the necessary adjustments to the IT systems will be more time-consuming and complicated
See MoreSouth Africa: Transfer Pricing Adjustments Regarding Withholding Tax Obligations
Under the income tax act, section 31(3), South Africa provide that any adjusted amount for transfer pricing and thin capitalization purposes, prior to 1 January 2015, constituted a deemed loan. The adjusted amount plus interest deemed to have
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