Philippines- to issue Advance Pricing Agreement (“APA”) procedures
First APA procedures to be released by the Bureau of Internal Revenue (“BIR”) in the Philippines. In order to meet the criteria for tax collection targets, the BIR is making considerable resources available in order to develop transfer pricing
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 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 MoreColombia: Updates on documentation threshold’s, audit penalty and APA
According to the Regulatory Decree 3030 of December 2013, transactions over 32,000 UVT by type of transaction are subject to transfer pricing analysis only if the total amount of the transactions exceeds 61,000 TVU. In the case of transactions with
See MoreFrance – Creation of new program for APAs and MAPs
The French tax authorities have announced the creation of a new program—Mission d’expertise juridique et économique internationale (MEJEI) - which will be responsible for both advance pricing arrangements (APAs) and mutual agreement procedures
See MoreItaly’s Transfer Pricing Changes In 2014
Italy has introduced a number of transfer pricing-related changes within its Finance Act 2014 (Law No 147/2013). These changes will have an effect on both administrative procedures and fundamental transfer pricing concepts. Article 1, Paragraph 281
See MoreGreece- Transfer Pricing Requirements regarding Financial Services and APA
The following requirements relative to financial services and Advance Pricing Agreement (APA) are described below: Financial Services: Financial services must follow the arm's length principle. It should also be noted that interest is deductible
See MoreUS agrees to tax talks with India under mutual agreement procedure
Following an approach by India the US tax authorities for finding a solution to tax cases of about 100 US companies that have opted for the Mutual Agreement Procedure (MAP), the US has now agreed for a meeting next month to discuss MAP, advance
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 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
See MoreGreece: Current transfer pricing legislation changes
Recently, major transfer pricing regulation changes have taken place in Greece. A bill was approved on 29 August 2013 by the Greek Parliament to expand the deadline for disclosing to the tax authority the inter-company transactions within a group
See MorePoland: Amendment on the Advance Pricing Agreements
Poland’s Ministry of Finance proposed changes on 11 June 2013 that might amend the provisions concerning advance pricing agreements (APAs) if sanctioned. Changes in the APA - Extended the scope of transactions to APAs by repealing current law
See MoreIndia: Extensive Guidance Note on APA
Recently the Central Board of Direct Taxes (CBDT) of India published a comprehensive APA Guidance Booklet concerning India’s advance pricing agreement (APA) program, detailing the procedural aspects of unilateral, bilateral or multilateral APA
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 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 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
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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