Indonesia publishes new regulations concerning advance pricing agreements
On 18 March 2020, the Indonesian Ministry of Finance released 22/PMK.03/2020 which updates the Advance Pricing Agreements (“APA”) regulations. The new regulations, effective 18 March 2020, include the following amendments: Previously
See MorePoland publishes a law implementing EU directive on dispute resolution and new provisions on APAs
On 14 November 2019, Poland published the Law of 26 October 2019 on resolution of disputes over double taxation and the execution of advance pricing agreements (the “Act”), which generally entered into force on 29 November 2019. The law
See MoreGermany publishes new draft of DAC 6 implementation law
On 26 September 2019, federal government of German issued a draft proposal regarding the implementation of mandatory disclosure rules pursuant to the EU’s Council Directive 2018/822 of 25 May 2018 (commonly referred to as DAC 6) into Germany’s
See MoreKazakhstan: Resolution No. 528 of 27 August 2018 publishes for amending APA process
According to Resolution No 528 of 27 August 2018 published on 6 September 2018, the review committee must complete its review within 60 working days of receipt of the application. If the application is approved, the signed contract should be sent to
See MoreTurkey: General Communiqué No. 3 regarding APAs publishes in the official gazette
The General Communiqué No. 3 regarding application process of Advance Pricing Agreements (APAs) was published on December 7, 2017 in the official gazette. It was entered into force on the similar day of its publication in the official gazette. The
See MoreMorocco: New procedures for APAs
Morocco published a Decree No. 2.16.571 of 3 July 2017 in the Official Gazette No. 6594 on August 10, 2017 that describes the procedure for concluding advance pricing agreements (APAs). This decree was published in Arabic language. For example, a
See MoreColombia: Tax reform 2016 and Transfer Pricing Updates
In accordance with law 1819 of 2016, adopting the structural tax reform bill approved on 23 December 2016, introduces the following main changes to the transfer pricing regime. According to article 260-3 of the Tax Code (TC), as amended by the tax
See MoreTurkey: Amendment in transfer pricing legislation
The Law No. 6728 on the amendment of certain laws for the improvement of the investment landscape has been published in the Official Gazette on 9 August 2016. This law amended certain transfer pricing provisions. Some of the provisions are given
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 MoreUkraine: Cabinet of Ministers adopts new advance pricing agreement procedures
Ukraine’s Cabinet of Ministers published Resolution No. 504 on 25 July 2015 regarding conclusion of advance pricing agreements (“APA”) in respect of controlled transactions for transfer pricing purposes. The new Resolution replaces the former
See MoreItaly: Draft legislative decree introduces advance pricing agreement rollback provision
A draft legislative decree was approved by the Italian Government on 21 April 2015 introducing an advance pricing agreement (APA) rollback provision and provisions relating to costs of transactions with tax havens. The draft decree introduces
See MoreIndia: Introduced rollback provisions under the Advance Pricing Agreement
The Finance (No.2) Act, 2014 introduced the rollback provisions under the Advance Pricing Agreement (APA) program. The rules have been notified / SO 758(E)] on 14 March 2015 setting out the applicability and the requirement for applying
See MoreSlovenia: APA concluded for transfer pricing purposes
On 1 August 2014, the amendments to the Financial Administration Law (the Law) entered into force. According to the law, the Tax Procedure Act effective from 2007 introduced a system of tax rulings and from 1 August 2014 advance pricing agreements
See MoreMexican tax reform of 2014 imposes deadlines for Maquiladora companies
The Mexican tax reform of 2014 has introduced a number of important changes for maquiladora enterprises. The changes apply to companies that are operating under the requirements of the Decree for the Promotion of the Manufacturing, Maquiladora and
See MoreVietnam – detailed guidance on APA process effective 5 February 2014
Following the introduction of Advance Pricing Agreements (APA) in the Revised Law on Tax Administration, Vietnam’s Ministry of Finance (MoF) issued Circular No. 201/2013/TT-BTC (Circular 201) providing detailed guidance on the APA application
See MoreVietnam: APA regime procedures and rules
Vietnam’s Ministry of Finance has issued detailed guidance in Circular 201/2013/TT_BTC dated 20 December 2013, for the advance pricing agreement (APA) regime, which was added to the income tax law in July 2013. The new guidance is effective from 5
See MoreRussia: Clarifications regarding the advance pricing agreements
The Ministry of Finance has released Letter 03-01-18/2676 on February 6, 2013 clarifying the procedure for concluding advance pricing agreements (APAs) for foreign transactions. According to article 105.20 of the Tax Code the Ministry of Finance
See MorePhilippines: New Transfer Pricing Regulations
The Philippines’ Secretary of Finance issued Revenue Regulations (RR) No. 02-2013 – the transfer pricing regulations – on 23 January 2013, which became effective from 9 February 2013. The new regulations provide guidance in applying the
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