India: The new Finance Act modifies the Transfer pricing law
On 5 July 2019, the Minister of Finance presented the Finance (No.2) Act for the financial year 2019-20. The act changes the following transfer pricing rules: Documentations requirements: Under the new amendments, constituent entity of an
See MoreIndia deposits ratification instrument for MLI
On 25 June 2019, India has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). According to Article 34, Paragraph 2 of the MLI, with
See MorePortugal approves MLI
On 21 June 2019, the Portugal's parliament approved the resolution for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). After the ratification process,
See MoreRussia deposits ratification instrument for MLI
On 18 June 2019, the Russian Federation has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). According to the date of deposit,
See MoreArgentina: Tax ruling on BEPS Action 5 minimum standard
On 30 May 2019, the Argentine tax authority published General Resolution No. 4497 (GR 4497/2019) in the official gazette amending the binding ruling (as established by Article 4 of Law No. 11,683) regulations, which adapts the Argentine tax
See MoreIndia: CBDT signs 18 new APAs
On 3 April 2019, the Central Board of Direct Taxes (CBDT) has announced the signing of 18 advance pricing agreements (APAs) during March 2019, including three bilateral APAs. With the signing of these APAs, the total number of APAs entered into
See MoreNetherlands: Draft regulations to revise international tax ruling policy
On 23 April 2019, the Dutch Undersecretary of Finance published a draft Decree containing regulations for the previously announced new Dutch international tax ruling practice. The draft Decree would be effective 1 July 2019. A version of a revised
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 MoreKazakhstan: New guidelines of TP Documentation and APA
On 24 December 2018, Mr. Alikhan Smailov, the Finance Minister of Kazakhstan approved forms and procedures for filling the Master files and Local files, effective from January 01, 2019. Generally, the rules for Master file and Local file are in line
See MoreIndia: CBDT signs first APA renewal
On 31 October 2018, the Central Board of Direct Taxes (CBDT) has signed a unilateral advance pricing agreement (APA) renewal. Accordingly, India reached another milestone as the first ever renewal of a unilateral APA. This renewal establishes
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 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 MoreIndia: CBDT signs first ever substantive revision to India-UK Bilateral APA
Recently, the Central Board of Direct Taxes (CBDT) signed the first ever substantive revision to an India-U.K. Bilateral advance pricing agreement (APA) due to certain changes in the way a particular transaction was being conducted. The changes were
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 MoreSwitzerland publishes guidance regarding mutual agreement procedure
The Swiss State Secretariat for International Financial Matters has released guidance for mutual agreement procedure (MAP) requests under Switzerland's tax treaties. Switzerland has concluded double taxation agreements with numerous countries.
See MoreBelgium issues a FAQs on MAP and APA
On 23 May 2018, the Public Federal Service (SPF) of Belgium published a document of FAQ on Mutual Agreement Procedure (MAP) and the Advance Pricing Agreement (APA) procedure. The assessee may also request that the tax due in Belgium is not invoiced
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