Portugal publishes new APA rules
On 26 November 2021, the Portuguese Tax Administration (PTA) was published Ministerial Order No. 267/2021 which revises the regulations on the procedures for concluding Advance Pricing Agreements (APAs) in accordance with Article 138 of the Code
See MoreIndia: CBDT notifies a formula to adjust MAT relief for secondary adjustment and APA
On 10 August 2021, the Central Board of Direct Taxes (CBDT) has published Notification No. 92/2021, which contains a new rule for calculating tax relief in the event of an increase in book profit as a result of adjustments to Advance Pricing
See MoreOECD: Peer review reports under BEPS Action 14
On 15 April 2021 the OECD released peer review assessments under Action 14 of the project on base erosion and profit shifting (BEPS) which aims to make dispute resolution mechanisms more effective. These stage two monitoring reports relate to
See MoreOECD: Transfer Pricing Implications of the Pandemic
On 18 December 2020 the OECD issued Guidance on the transfer pricing implications of the COVID-19 pandemic. This looks at the impact of the pandemic on areas of the transfer pricing analysis and APAs. Comparability analysis The pandemic and
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UK: Updated Statistics on Transfer Pricing and Diverted Profits Tax
On 12 November 2020 HMRC published updated statistics relating to transfer pricing and the diverted profits tax for 2019/20 (the year to 31 March 2020). In 2019/20 a total of 125 transfer pricing enquiries were settled, with an average
See MoreDominican Republic: DGII updates transfer pricing brochure
On 7 February 2019, The Dominican Republic’s Directorate General of Internal Revenue (DGII) published online brochure to update guidance on transfer pricing. The brochure makes a number of following changes on transfer pricing: Reporting
See MoreIndia: CBDT signed first bilateral APA with US
On 5 January 2018, the Indian Central Board of Direct Taxes (CBDT) signed the first bilateral advance pricing agreement (APA) with the United States. The CBDT has also indicated that there are many more bilateral APAs with the United States
See MoreIndia clarifies position on acceptance of the MAP and bilateral APA
On 27 November 2017, the Indian Government has announced that the MAP for transfer pricing disputes and the bilateral advance pricing agreement (APA) process would be available to taxpayers even where Article 9(2) or the equivalent is not present in
See MoreIndia: CBDT signs two new APAs
On 6 October 2017, the Ministry of Finance issued a press release announcing that the Central Board of Direct Taxes (CBDT) has signed two more advance pricing agreements (APAs) in September 2017 with Indian taxpayers. These two latest APAs relate to
See MoreIndia: CBDT issues first comprehensive report on APA
On May 1, 2017, the first annual report on APA programme was released by the Central Board of Direct Taxes (CBDT) which provides various statistical and qualitative aspects of the Indian APA program to promote discussions and discussions between
See MoreIndia: CBDT signs four more unilateral APAs
On 6th February 2017, the Central Board of Direct Taxes (CBDT) has signed four more unilateral advance pricing agreements (APAs) with Indian taxpayers in order to reduce litigation by providing certainty in transfer pricing. The international
See MoreMalaysia: Corporate tax proposals under the finance act 2016
The Finance Act 2016, which was gazetted on 16 January 2017, introduces new corporate tax proposals to the Malaysian Income Tax Act (MITA). The highlighted area of the proposals is as given below; Special classes of income are subject to withholding
See MoreSlovenia: Publishes advance pricing agreement rules
Details on the introduction of Advance Pricing Arrangements (APAs) are now available in the Official Gazette on 28 December 2016. Accordingly, the following rules will apply from January 2017: (i) The application of APA must be addressed to the
See MoreSlovak Republic: Tax law amendments approved
Suggested amendments to corporate income tax, individual income tax, transfer pricing and special levies in case of companies in regulated industries has been approved by the parliament on 23rd November 2016. The amendments have not yet been
See MoreSlovak Republic: Introduction to country-by-country reporting
The legislative bodies of Slovakia has issued a bill amending Act No. 442/2012 Coll. on international assistance and cooperation in tax administration that introduces the country-by-country (CbC) reporting obligation in Slovakia. The draft
See MoreSlovak Republic: Tax law amendments proposed
A governmental package of proposed amendments on tax law has been submitted to the parliament and the changes are suggested to become effective from 1st January 2017. These changes needs to be approved by the parliament and signed by the President
See MoreItaly: Tax Authorities Issue Regulation to Clarify APA Procedure
The director of the Italian Revenue Office (Agenzia delle Entrate) issued regulation no. 42295/2016 (the regulation) on March 21 2016 which contains provisions for the application of the rules on advance pricing agreements (APAs) for enterprises
See MoreIreland: Advance pricing agreement regime announced
The Irish revenue authority has announced that it will introduce a formal Advance Pricing Agreement (APA) program and are expected to be published in 2016. Ireland has accepted and concluded bilateral advance pricing agreements (APAs) for many years
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