US: Tax Court issues an opinion in the case of Eaton Corp. v. Commissioner regarding APA
On 28 October 2019, the U.S. Tax Court published an order in the case of Eaton Corp. v. Commissioner related to advance pricing agreements (APAs). In that case, Eaton Corporation (P-Petitioner) and Commissioner of Internal Revenue
See MorePoland: Government publishes draft bill introducing simplified APA procedure
On 22 March 2019, Poland’s legislative centre published a draft bill that addresses dispute resolution of double taxation issues and advance pricing agreements (APAs). Under this taxpayers will be benefited from the new procedure on Simplified
See MoreUS: APMA releases new functional cost diagnostic model (FCD model) for APA submissions
On 26 February 2019, Advance Pricing and Mutual Agreement (APMA) program of IRS, released an excel based functional cost diagnostic model (FCD Model) that is developed in connection with several prior and pending Bilateral Advance Pricing
See MoreIndia: CBDT publishes second APA annual report
The Central Board of Direct Tax (CBDT) released the second annual report (2017-18) of its advance pricing agreement (APA) programme on 31 August 2018. The report introduced a report card of the performance of the programme along with qualitative and
See MoreJamaica: TAJ publishes practice note on final version of transfer pricing agreement
Tax Administration Jamaica (TAJ) recently published the final version of a Transfer Pricing Agreement (TPA) Practice Note. The purpose of the Practice Note is to provide taxpayers and tax officials with guidance on transfer pricing agreements in
See MoreCanada: CRA publishes 2017 APA Program Report
The Canada Revenue Agency (CRA) has published an annual report on its APA program since the 2001 to 2002 fiscal year. Since 2016, the annual report has been based on a calendar year, whereas the previous annual reports were based on a fiscal year.
See MoreTurkey: Council of Minister proposes transfer pricing provisions
A draft Communique regarding transfer pricing has been published in Turkey. It generally represents measures of the OECD’s base erosion and profit shifting (BEPS) Action 13 on country-by-country reporting and transfer pricing documentation. The
See MoreCroatia publishes the guidance on Advance Pricing Agreements (APAs)
The Minister of Finance, pursuant to Article 14a of the Law on Profit Tax, has issued the ordinance on the procedure for concluding the previous transfer pricing agreement. The ordinance was published in the Official Gazette No. 42/17 on 3 May 2017
See MoreIreland published new APA guidelines
The Irish Revenue published bilateral advance pricing agreement guidelines on June 23 relating to the operation of Ireland’s APA program, which is effective for applications received on or after July 1, 2016. The guidance outlines the framework of
See MoreRomania: Government publishes new Orders on tax rulings and APAs
The Romanian Government published Orders at the end of 2015 regarding binding tax rulings and advance pricing agreement (APAs). Under the provisions on binding tax rulings the tax situation that is to be the subject of the ruling must be in the
See MoreItaly: Published Legislative Decree on Transfer Pricing Issues in the Official Gazette
Italy Published Legislative decree n. 147 in the official gazette on 22 September 2015 with a view to provide investors with certainty arising from their investment plan. As per the published Legislative decree, expenses relating to the transactions
See MoreUS: IRS Issued New Revenue Procedures on Competent Authority and Advance Pricing Agreement
The IRS has issued two revenue procedures on August 12, 2015 with details guidance to request assistance from the US competent authority under income tax treaties and to obtain an advance pricing agreement (APA) program. The proposed version of
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 MoreSpain: Modifies the transfer pricing legislation
In the “Corporate Income Tax Reform 2015” enacted under the Law 27/2014 the following transfer pricing rules are amended; Scope of related-party transactions - The ownership requirement for related parties is increased from 5% (1% in the
See MoreSlovenia: Financial administration approved to conclude advance pricing agreements
In Slovenia, the amendments to the Financial Administration Law (the Law) entered into force on 1st August 2014. This Law Based on financial authorities is authorized to conclude advance pricing agreements (APA) for transfer pricing purposes. The
See MorePeru: Published regulation for advance pricing agreement
The tax authority's Resolution 377-2013/SUNAT, published in the Official Gazette on 29 December 2013.Accordance with the Resolution 377/2013, intention to negotiate an APA should be expressed in writing to SUNAT which must reply within 15 days.
See MoreUS: Report on advance pricing agreements
The US report on advance pricing agreements issued on 25 March 2013 covers the activities of the program in 2012. At the beginning of 2012 the APA program was merged with the office of the competent authority (USCA) that is responsible for the
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
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