Canada: 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 MoreRussia publishes bilateral and multilateral APA Procedure
On 3 May 2018, Russia published Decree No. 60 on the Official Gazette, which approves the procedures for the conclusion of advance pricing agreements (APAs). The Russian Finance Ministry delegated the competent authority powers with respect to
See MoreIndia: CBDT signs seven more unilateral APAs
On 1 March 2018, the Ministry of Finance issued a press release announcing that Central Board of Direct Taxes (CBDT) had signed seven further Advance Pricing Agreements (APAs) in February 2018. All seven are unilateral APAs covering the
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 MoreTurkey: Revenue Administration publishes draft Communiqué 3 on APAs
The Revenue Administration published draft General Communiqué No. 3 on October 24, 2017 regarding transfer pricing. This provides amendments to Section 6 of General Communiqué No. 1. According to draft General Communiqué No. 3, definitions of
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 MoreIndia signs fifth bilateral advance pricing agreement with Japan
On 6 March 2017, India has signed a bilateral advance pricing agreement with the Indian subsidiary of a Japanese company, India's Central Board of Direct Taxes (CBDT) has announced. With this agreement, India and Japan have concluded five bilateral
See MoreTurkey: Bilateral APA signed
The Revenue Administration stated on 30th December 2016 that it had signed a new bilateral advance pricing agreement and this agreement is based on article 13 of Corporate Income Tax Law No.
See MoreUruguay-Bill on adoption of CbC reporting, Master file documentation and the availability of bilateral and multilateral APAs
The Uruguay Government has submitted to Congress a tax bill including adoption of the OECD’s recommendations for Country-by-Country (CbC) reporting following the scope of information to be provided under the Base Erosion and Profit Shifting (BEPS)
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 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 MoreIndia & Japan: First bilateral APA signed
The Central Board of Direct Taxes (CBDT) signed a bilateral Advance Pricing Agreement (APA) with a Japanese company on 19 December 2014. This is India’s first bilateral APA which has been signed for a period of 5 years. Moreover, CBDT was proud to
See MoreChina-US: Third Bilateral Advance Pricing Agreement Signed
In September 2013, China’s State Administration of Taxation and the U.S. Internal Revenue Service reached an agreement in principle on their third bilateral advance pricing arrangement. China and the United States concluded their second bilateral
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