Transfer Pricing Brief: July 2016
Austria: BEPS Related Compliance Master file information: Austria has introduced a requirement for a master file for constituent entities resident in Austria if their turnover in the previous two fiscal years exceeded €50 million in each year.
See MoreIreland published new APA guidelines
The Irish Revenue published bilateral advance pricing agreement guidelines on June 23 relating to the operation of Ireland’s APA program, which is effective for applications received on or after July 1, 2016. The guidance outlines the framework of
See MoreMexico: Government passes new transfer pricing rules for APA
The Mexican government recently passed a new regulation to permitting the Mexican Tax Authorities to perform on-site visits to carry out their own functional analysis as a part of the Advanced Pricing Agreement (APA) process. Rule 2.12.8 published
See MoreRussia: Notification of tax authorities concerning CFCs
The Finance Ministry (MoF) has issued a Letter No. 03-01-23/30779 on 27th May 2016 for clarifying the responsibility of taxpayers to notify the tax authorities about CFCs. On the basis of section 3.1 of article 23 of the Tax Code, taxpayers have to
See MoreSlovak Republic: MoF publishes a guideline regarding TP documentation
The principle of transfer pricing is the pricing of goods, services and so on in related party transactions surrounded by multinational enterprises to fulfill the conditions for a self-governing business relationship or to meet the arm’s length
See MoreGreece: Bill regarding transfer pricing provisions enacted
The Greek Parliament has approved a bill of the Finance Ministry on 27th July 2016 introducing significant changes regarding the transfer pricing documentation provisions. The bill, inter alia, amended various provisions of the Greek Tax Procedure
See MoreOECD: Addressing BEPS involving interest in the banking and insurance sectors
On 28 July 2016 the OECD issued a discussion draft outlining approaches to combating base erosion and profit shifting (BEPS) involving interest in the banking and insurance sectors. This is part of further work following the final report on BEPS
See MoreUK: Statistics for Creative Industries Tax Relief
On 20 July 2016 the UK published updated statistics on claims for creative industry tax relief. The statistics include data for the film tax relief, high end television tax relief, animation tax relief and video games tax relief for periods up to
See MoreOECD: Report to G20 finance ministers
On 26 July 2016 the OECD published on its website the report prepared for the meeting of the G20 finance ministers held on 23 and 24 July 2016. The report contains updates on progress on the implementation of the recommendations of the reports on
See MorePlatform for Collaboration on Tax: Report to G20 on capacity building
On 25 July 2016 the Platform for Collaboration on Tax made available a report on enhancing the effectiveness of external support in building tax capacity in developing countries. The report was written for the meeting of the G20 finance ministers
See MoreChina issued new rules on TP documentation requirement
China issued Bulletin 42 to introduce a requirement for a master file for MNC group resident in China if their annual inter-company transaction amount exceeds RMB 1 billion. The master file requirement is effective from fiscal year 2016. A master
See MoreBelgium issued new rules on CbC reporting and TP documentation requirement
Belgium issued regulation to introduce a requirement for a master file and a local file for MNC group resident in Belgium if it satisfies one of the three thresholds like a sum of operational and financial income of €50 million; or a balance
See MoreKorea: Revised draft legislation on transfer pricing and country-by-country reporting
The South Korean Ministry of Strategy and Finance has recently released a draft legislation which would amend the existing provisions of Article 11 of the Korean Law which is known as the “Law for the Coordination of International Tax Affairs”
See MoreColombia: New regulation on late payment interest rate
The Financial Supervisory Authority of Colombia recently issued Administrative Regulation 0811 of 2016 about the late payment interest rate. According to the Regulation, the effective annual interest rate is 32.01% that applicable for late payment
See MoreAustria: Publishes government bill of new Transfer Pricing Documentation Law
Finance (MoF) published the government bill of the European Union (EU) Tax Amendment Act 2016, including among other provisions, the new Austrian Transfer Pricing Documentation Law (TPDL). This follows the publication of the draft TPDL on 9 May 2016
See MoreG20 Finance Ministers support equitable growth
The G20 finance ministers and central bank governors met on 23 and 24 July 2016 and issued a final communiqué on 24 July 2016. In the final communiqué the finance ministers and central bank governors noted that the benefits of economic growth
See MoreIndia: Tribunal held that Transfer Pricing Officers have the authority to determine the arm’s length price
The Delhi Bench of the Income-tax Appellate Tribunal in the case of: Nikon India Pvt. Ltd. v. DCIT (ITA No. 6314/Del/2015), held that Transfer Pricing Officers have the authority to determine the arm’s length price of any international transaction
See MoreIndia: CBDT amends rules relating to GAAR effective date
The Central Board of Direct Taxes (CBDT) issued Notification No. 49/2016 (the Notification) dated 22 June 2016 on the effective date of the general anti-avoidance rules (GAAR). According to the Notification, the amendments to the Income Tax Rules,
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