US: IRS issues new advance pricing agreement (APA) template
On May 11, 2018, the IRS’s Advance Pricing and Mutual Agreement Program (APMA) issued a new template that taxpayers must use when requesting an advance pricing agreement (APA) under Rev. Proc. 2015-41, 2015-35 I.R.B. 263 (Rev. Proc. 2015-41).
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 proposes changes in advance ruling forms for transparency in cross-border deals
On 10 April 2018, the central board of direct taxes (CBDT) issued a draft which includes changes to the income tax rules and forms to align them more closely with the OECD’s base erosion and profit shifting (BEPS) Action 5. The draft essentially
See MoreUS: IRS publishes annual advance pricing agreement report for 2017
On 30 March 2018 with an announcement, IRS published Advance Pricing Agreement (APA) report for the calendar year 2017. The report describes the experience, structure, and activities of the APMA Program during calendar year 2017. It does not provide
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 MoreUS: IRS increases the fees for advance pricing agreements
On 6 February 2018, the Internal Revenue Service (IRS) announced that fees for Advance Pricing Agreements (APAs) are expected to increase in a two-step process. For APA requests submitted after June 30, 2018, the fees will increase as follows:
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 MoreMalaysia: IRBM amends the APA rules and updates the MAP guidelines
Recently, the MIRB (Malaysia Inland Revenue Board) has published an amendment to the APA Rules and the updated Mutual Agreement Procedure (“MAP”) Guidelines. The APA rules referred to as the Income Tax (Advance Pricing Arrangement) Rules 2012
See MoreArgentina: Government reforms transfer pricing rules via Decree 1112/2017
The government has issued a Decree No.1112/2017 on December 29, 2017, for enacting and making effective of comprehensive tax reform. It also contains the new rules for transfer pricing. According to the new Law, transactions with parties in low-tax
See MoreUkraine changes in Transfer Pricing Rules from January 1, 2018
On 7 December 2017, the Ukrainian Parliament passed the Law of Ukraine "On Amendments to the Tax Code of Ukraine and Certain Laws of Ukraine on Securing Balance of Budget Revenues in 2018” No. 2245-VIII (“Law”). The law came into force on 1
See MoreUS: IRS releases practice units on APAs for tangible goods transactions
On November 6, 2017, the Internal Revenue Service (IRS) released two new international Practice Units (IPUs) in connection with Advance Pricing Agreements (APAs) for inbound and outbound tangible goods transactions. The IPUs provide a summary of 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 MoreUnited States: IRS issues draft advance pricing agreement (APA) template for public comment
The US Internal Revenue Service (IRS) has recently published on its web page that the IRS’s Advance Pricing and Mutual Agreement Program (APMA) is soliciting comments on a proposed revision to the template for advance pricing agreements (APAs).
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 MoreBelgium adopts draft bill to implement EU directives on automatic exchange of information
The Belgian parliament adopted the draft bill to implement the EU Directive 2014/107/EU for mandatory automatic exchange of information, on 20 July 2017 and the bill was published in the Belgian Official Gazette, on 11 August 2017. The Bill
See MorePanama aims to introduce advance pricing agreements
Panamanian Tax Authority (DGI) began a consultation to amend Article 762-L of the tax code to introduce advance pricing agreements (APAs) on transfer pricing issues. The DGI has twelve months to issue a decision and the decisions of the DGI are
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
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