Transfer Pricing Brief: March 2015
Australia Transfer pricing rule-The practice statement (PS LA 2015/3) issued on 26 February 2015 sets out a new internal approval process for application of the reconstruction provisions. See the Story in
See MoreFrance: New steps to improve relationship between tax administration and companies
The Ministry of Finances and Public Accounts and the Ministry of Economy and Industry announced a set of measures to fight tax fraud on 1 April 2015. The measures also fight against tax evasion at national, European and international level, and
See MoreOECD releases discussion draft on mandatory disclosure rules
On 31 March 2015 the OECD released a discussion draft in respect of Action 12 of the action plan on base erosion and profit shifting (BEPS). Action 12 calls for disclosure initiatives to deal with the lack of relevant information for tax
See MoreUK: New version of company tax return form introduced
HM Revenue and Customs (HMRC) has introduced a new version of the tax return form for companies. Form CT600 version 3 should be used by companies for accounting periods beginning on or after 1 April 2015. A new computation taxonomy has been
See MoreSouth Africa: SARS Issues Tax Guide For Non-Residents
The South African Revenue Service (SARS) has issued a tax guide for the tax treatment of South Africa-sourced income of non-residents. The guide mainly focuses on employment income. Non-resident individuals are required to register with SARS and
See MoreNigeria: IMF comments on fiscal policy
The International Monetary Fund (IMF) has concluded bilateral discussions with Nigeria under Article IV of the IMF’s articles of agreement. The staff report together with a selected issues paper commenting on Nigeria’s economic situation were
See MoreQatar: IMF makes recommendations on fiscal policy
On 2 April 2015 the IMF published on its website a staff report and selected issues paper in respect of discussions with Qatar under Article IV of the IMF’s articles of agreement. The IMF has looked at the economic situation and has made
See MoreLithuania: IMF comments on fiscal policy
The IMF has published a report of its preliminary findings following a visit to Lithuania for consultations on economic policy. The report finds that Lithuania’s economic growth in recent years has been among the strongest in Europe. Growth is
See MoreSwitzerland: Completes corporate tax reform III
The Swiss Federal Council issued its parameters for the dispatch on the Corporate Tax Reform III on 2 April 2015 and The Federal Department of Finance will arrange a dispatch on the new rules by June 2015. After it has been accepted by the Council,
See MoreCanada: Federal budget due 21 April 2015
Finance Minister will deliver the Conservative government’s federal budget for 2015 on 21st April 2015. It is being expected that the budget is to be balanced and will set the platform for Conservative government’s tax and financial policies due
See MoreRussia: Law concerning notification process of CFCs adopted
The parliament has approved Law No. 667946-6 on 27th March 2015 for extending the deadline of tax resident’s notification about the involvements held in controlled foreign companies (CFCs). The deadline for notification has been extended from 1st
See MoreDenmark: Information Published on Transfer Pricing cases
The Ministry of Taxation published on 11 March 2015 information regarding the transfer pricing (TP) adjustments made in 2014 and the main transfer pricing focus areas for 2015. During 2014, the tax authorities dealt with 76 transfer pricing cases,
See MoreChina: Tax Authority’s Plans to Review all Outbound Payments to Overseas Related Parties
The State Administration of Taxation (SAT) has released the Public Notice on March 26, 2015 regarding certain corporate Income Tax matters on Outbound Payments to Overseas Related Parties. Public Notice 16 states that outbound payments to overseas
See MoreRussia: State Duma considers new draft law regarding thin capitalization rules
The Russian State Duma Council accepted the decision on 17th February 2015 to incorporate a new draft of Law No. 724609-6 on the introduction of changes to Article 269, Part 2 of the Tax Code regarding the meaning of controlled debt. The draft law
See MoreUK Issues Guidance on the Diverted Profits Tax
The UK included legislation to introduce the Diverted Profits Tax in the Finance Bill for 2015. Guidance on the tax was updated on 30 March 2015 to explain the changes to the provisions since the draft legislation was first published. The guidance
See MoreIndia: Extends Time for Filing Roll-back Applications under APA
The Central Board of Direct Tax authorities announced that the deadline for filing APA (Advance Pricing Agreement) rollback applications has been extended to 30 June 2015. Originally, the date for filing rollback applications was 31 March
See MoreRomania: IMF Comments on Fiscal Policy
The IMF issued a report on 27 March 2015 following the conclusion of Article IV consultations with the Romanian government. The economic recovery following the financial crisis has become broad based in Romania and economic growth is remaining
See MoreGermany: New regulations approved by German Parliament on the application of the arm’s length principle to profit allocations
New regulations approved by The Upper House of the German Parliament on the application of the arm’s length principle to profit allocations between head office and permanent establishments, which follow the authorized OECD approach (AOA) and is
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