Indonesia: New Regulation on Transfer Pricing Audits
Regulation PER 22/PJ/2013 has been published by the Indonesia’s Directorate General of Taxation (DGT) on 30 May 2013 to provide guidelines for audits of taxpayers with related-party relationships and repealed the regulation KEP-01/PJ 07/1993
See MoreIndia: CUP method for benchmarking service contracts
In a recent decision of Income Tax Appellate Tribunal (“ITAT”) it was held that for benchmarking service contracts when comparable data for these contracts is available the comparable uncontrolled price (CUP) method is the most suitable method.
See MoreHungary: New Decree on Transfer Pricing Documentation Rules
The Hungary’s Ministry of Finance has issued Decree 20/2013 on 18 June 2013. The decree clarified the transfer pricing documentation obligations of Hungary. The Decree 20/2013 is designed to decrease the taxpayers’ administrative burden and to
See MoreFrance: report on tax evasion, transfer pricing
The French Minister of Economy and Finance published an official report on transfer pricing legislation on 5 June 2013. The report concludes that France’s transfer pricing rules are out of step with international counterparts. The French General
See MoreECJ rules on relevance of contractual terms in VAT supply
The European Court of Justice (ECJ) has reached a decision in the case of HMRC v Paul Newey t/a Ocean Finance (C-653/11). This case concerned the relevance of contractual terms to the identification of the supplier and recipient of services for the
See MoreECJ: Advocate General issues opinion on VAT and educational services
A question was referred to the ECJ by the Supreme Court of Poland in respect of VAT on educational services. The Advocate General has now issued an opinion on the case, which is however not binding on the ECJ which will issue its decision at a later
See MoreCzech Republic: New Decree on Low Value Adding Services
The General Financial Directorate (D-10) has issued the new Decree related to Low Value Adding Services took into effect on January 1, 2013 and it will relief qualifying taxpayers from preparation of full-phase transfer pricing documentation and
See MoreUK: consultation on allowing the transfer of savings in child trust funds to junior ISAs
The UK government has published a consultation document in respect of allowing the transfer of savings from a Child Trust Fund to a junior Individual Savings Account (Junior ISA). Child trust funds were originally introduced in 2004 with the
See MoreUK: Double tax agreement with the Netherlands on bank taxes
The UK and the Netherlands signed a double tax convention on 12 June 2013 in respect of bank taxes. The taxes covered by the Convention are the UK bank levy under Schedule 19 FA 2011 and the tax charged under the Netherlands law on bank tax. The
See MoreTanzania: Tax proposals for 2013 budget
The Tanzanian Budget for 2013 was presented to the National Assembly by the Minister of Finance and key changes made by the Budget proposals are summarized below: Reduction of the minimum tax rate for individuals from 14% to 13%. Abolition of a
See MoreRomania: Corporate tax rate remain unchanged
The Prime Minister of Romania has confirmed that the country’s 16 percent flat rate of corporation tax will be kept until 2016. The rate is being kept the same to provide investors with more stability and certainty in taking investment decisions
See MorePoland: Amendment on the Advance Pricing Agreements
Poland’s Ministry of Finance proposed changes on 11 June 2013 that might amend the provisions concerning advance pricing agreements (APAs) if sanctioned. Changes in the APA - Extended the scope of transactions to APAs by repealing current law
See MoreKenya: Tax proposals in the 2013/14 budget
The National Assembly by the Cabinet Secretary to the National Treasury was presented the Budget for 2013-14 on 13 June 2013 . Capital gains tax has been re-introduced and applies to real estate, marketable securities and other saleable assets.
See MoreIndia: Transfer Pricing Reporting Requirements
Recently India’s Central Board of Direct Taxes issued guidance that expands the transfer pricing reporting requirements of certain international transactions and certain “specified domestic transactions.” To bring into line those reporting
See MoreIndia: Extensive Guidance Note on APA
Recently the Central Board of Direct Taxes (CBDT) of India published a comprehensive APA Guidance Booklet concerning India’s advance pricing agreement (APA) program, detailing the procedural aspects of unilateral, bilateral or multilateral APA
See MoreIndia: Listed price cannot be used under the Comparable Uncontrolled Price (CUP) method
In a recent decision, the Chennai Bench of the Income-tax Appellate Tribunal held that the list price on a manufacture’s website is only an “indicative price” and so the list price alone cannot be used to determine the arm’s length price of
See MoreFrance: IGF recommends strengthening control of transfer pricing
The French tax authorities released a report on 11 June 2013 regarding recommendations aimed at strengthening existing transfer pricing rules applicable to international groups in France, to better combat tax optimization and avoidance by
See MoreECJ: Ruling on freedom of provision of services by banks
The European Court of Justice (ECJ) ruled on 6 June 2013 in Commission v Belgium (C-383/10) that Belgium had failed to fulfill its responsibilities under Article 5 of the Treaty on the Functioning of the European Union (TFEU) and Article 36 of the
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