Greece: 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 MoreIndia: APA for earlier year may apply, determining “tested party”
Recently, the Delhi Bench of the Income-tax Appellate Tribunal (the Tribunal) in case of: Ranbaxy Laboratories Ltd. v. ACIT (ITA No. 196/Del/2013), held that overseas Associated Enterprises (AEs) being least complex entities in the transaction,
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 MoreIreland’s Revenue published the Manual on role of the competent authority
On 9 November 2015, the Irish Revenue issued a manual regarding the role of the Irish competent authority in resolving international tax disputes and ensuring the correct allocation of taxable profits to Ireland. Mutual agreement procedures
See MoreNew Zealand: Inland Revenue revises its guidance on APA
Inland Revenue recently updated its guidance on the Advance Pricing Agreement (APA) application process and published a list of steps aiming to standardize the process. Agreements can be required from Inland Revenue alone (unilateral) or between
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 MoreCanada: CRA issues 2014-15 APA program report
The Canada Revenue Agency (CRA) has published a report on 17th August 2015 regarding Advance Pricing Arrangement (APA) program for the period from 1st April 2014 to 31st March 2015. This gives an overview of the systems of APA program containing
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 MoreNew guidance on Advance Pricing Agreements issued by Australian Taxation Office
The Australian Taxation Office released its revised policies and procedures for the Advance Pricing Agreements program on 23 July 2015. The updated guidance has been provided in the form of Practice Statement Law Administration PSLA 2015/4, which
See MoreSlovenia: Procedures for Advance Pricing Agreements
The Ministry of Finance has published proposed changes to the Slovenian Tax Procedure Act. The envisaged amendments bring a broad variety of important amendments regarding automatic exchange of information and elimination of administrative
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 MoreTurkey: Draft guidance on APA applications
The Turkish revenue administration released draft guidance in early April 2015 on advance pricing agreements (APAs). The guidance sets out the information that may be requested by the tax authorities in order to review APA applications. In
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 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 MoreSingapore: New Revised Transfer Pricing Guidelines for 2015
The Inland Revenue Authority of Singapore (IRAS) publishes revised transfer pricing (TP) guidelines on 6 January 2015. The 2015 TP Guidelines are generally in line with the OECD Transfer Pricing Guidelines (2010) as well as some relevant areas of
See MoreKorea: Unilateral APA program introduced
A simplified APA (Advance Pricing Agreement) program is to be introduced from 2015 for the conclusion of unilateral APAs by manufacturers, wholesalers, retailers or service providers with revenue under KRW 50 billion. Applicants will be able to
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
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