Chile: Issuance of Resolution No. 14 of 2013
Resolution No. 14 of 2013 has been issued by the Chilean Internal Revenue Service (Chilean IRS) that contains the new Transfer Pricing Annual Informative Return for calendar year 2012 and the proper completing instructions. The deadline for filing
See MorePoland – Reviewed tax haven list, transfer pricing documentation
Poland’s Ministry of Finance proposed to change the rule and regulation containing the list of countries and territories that are identified as applying “harmful tax competition on March 8 2013”. After finalizing the changes the Polish
See MoreNamibia: Budget for 2013-14
The Minister of Finance of Namibia presented its Budget for 2013-14 to the National Assembly on 26 February 2013. Details of the Budget, which unless otherwise indicated will apply from 1 March 2013. In the Budget 2013-14 it has been proposed for
See MoreDanish Government plans to reduce corporate income tax rate
On 26 February 2013, the government published a document stating that it plans to reduce the corporate income tax rate to 22% (currently 25%). The reduction would be implemented gradually by reducing the tax rate by 1 percentage point between the
See MoreTransfer Pricing Brief: February 2013
Brazil Alternative methods can be used in the case of fixed interest loans in US dollars or Brazilian Reais. A safe harbour rule applies in respect of documentation requirements for export transactions. Specified margins are required in respect of
See MoreTransfer Pricing Brief: January 2013
Austria The Austrian Independent Fiscal Senate (UFS) in decision UFSW, GZ RV 2515-W/09 suggested that the use of an interquartile or a full range depends on the quantity and quality of results of the benchmarking study. A small sample of six
See MoreTransfer Pricing Brief: December 2012
Belgium From 1 January 2013 capital gains made by companies on the disposal of shares are to be taxed at a rate of 0.4% (plus a 3% crisis contribution). Brazil Under Private ruling 8/2012 of 8 November 2012, contributions to a CCA are allowable if
See MoreTransfer Pricing Brief: November 2012
Chile The CUP method is permitted by Law 20,630 effective from 1 January 2013. As regards to the documentation requirements taxpayers will have to file an annual transfer pricing return containing information on foreign related parties,
See MoreTransfer Pricing Brief: October 2012
Chile The main corporate income tax rate is 20% for 2012. Under Law 20,630 amending the transfer pricing rules where an adjustment is made the shortfall is to be treated as a distribution and taxed at a 35% rate, with a penalty of 5%. Law 20,630
See MoreTransfer Pricing Brief: September 2012
Australia A new subdivision 815-A has been passed in 2012 in respect of treaty equivalent cross-border transfer pricing rules. The Commissioner is empowered to challenge the extent of interest deductions in a situation where the level of related
See MorePoland – Changes to transfer pricing documentation, thin capitalization rules
Legislation to expand the scope of Poland’s corporate income tax law is intended to be effective in 2014. The provisions of the legislation released on February 18, 2013 include changes to the transfer pricing documentation and thin capitalization
See MoreIndia: Budget for 2013
According to the Indian Budget 2013, the Government is considering for following major tax initiatives: the introduction of a Direct Tax Code (DTC), a goods and services tax (GST) and General Anti-Avoidance Rules (GAAR). The main changes are
See MoreGreece: Introduction of new Advance Pricing Agreement and Improvements of transfer pricing framework
Tax Law 4110/2013 was circulated in the Govt. Gazette on 23th January 2013. Aside from some major amendments on taxation of natural person and corporate income taxation, the new law includes an improvement of the Greek transfer pricing regulatory
See MorePortuguese Court’s decision in transfer pricing dispute relating to inter-company loan and management fees
The arbitration administrative court in Portugal recently ruled in favour of the taxpayer in a dispute with the Portuguese Tax Authorities (TA) in respect to the application of the arm’s length principle to inter-company loan and management fee
See MoreUnited States: IRS publishes quarterly list of individuals who have expatriated.
The US Internal Revenue Service has published a quarterly notice with a list of US citizens and long-term US residents who have renounced their citizenship or residency for US federal tax purposes. The Notice is dated 29 January 2013, and is based
See MoreJapan: For 2013 tax reform proposals
The Tax Commission of Japan has submitted 2013 tax reform proposal on January 29, 2013 upon approval by the Cabinet. The suggested reform will be submitted to the Diet during February 2013 for consideration. The proposed main changes are summarized
See MoreChile: New Transfer Pricing Compliance Requirement
A new transfer pricing compliance requirement has been introduced in Chile by Resolution No. 14 of 2013. According to the new rule Chilean taxpayers are required to file a Transfer Pricing Annual Informative Return (‘TP Return’) for calendar
See MoreAustralia: New Transfer Pricing Legislation
On 13 February 2013, the Federal Government introduced legislation on 13 February containing new Australian Transfer Pricing Laws. These are largely consistent with the Exposure Draft (ED), released in November 2012. The new enactment adjusts
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