Ukraine: Cabinet of Ministers adopts the changes to advance pricing agreements
The Cabinet of Ministers of Ukraine on March 29, 2017 adopted amendments to the Regulation No. 504 of 17 July 2015 regarding the procedure of issuing advance pricing agreements (APAs). According to the adopted amendments to the Regulation No. 504 of
See MoreCyprus: Council of Ministers approves Multilateral Instrument signing to OECD
According to a press release issued by the Finance Ministry, the signing of the “Multilateral Instrument” has been approved by the Council of Ministers on April 5, 2017. Therefore, Cyprus is going to sign the ‘Multilateral Convention to
See MoreUS: IRS releases annual report on advance pricing and mutual agreement program for 2016
The IRS has issued its annual report on advance pricing agreements (APAs) and the Advance Pricing and Mutual Agreement (APMA) Program (formerly the Advance Pricing Agreement (APA) Program). The report was issued as IRS Announcement 2017-3 dated 27
See MoreTurkey: Announcement of unilateral APA signed
The Tax Administration of Turkey declared an announcement on 20th March 2017 that it had signed a new unilateral Advance Pricing Agreement (APA) on 1st March 2017. The APA is prepared on the basis of article 13 of Corporate Tax Law No.
See MoreChina concludes first cost sharing agreement APA
The State Administration of Taxation (SAT) of China recently concluded the first advance pricing agreement (APA) for a cost sharing agreement (CSA) with a Fortune 500 enterprise in Guangdong Province. The CSA-APA focuses on international R&D
See MoreRussia: Publishes the draft procedure on multilateral APAs
The Russian Finance Ministry on 3 March 2017, published a draft Procedure outlining the process for handling multilateral Advanced Pricing Agreements (APAs). The Procedure is intended to enable a taxpayer to conclude an APA in relation to a foreign
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 MoreColombia: Tax reform 2016 and Transfer Pricing Updates
In accordance with law 1819 of 2016, adopting the structural tax reform bill approved on 23 December 2016, introduces the following main changes to the transfer pricing regime. According to article 260-3 of the Tax Code (TC), as amended by the tax
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 MoreChina published a report of APAs 2015
On 23 December 2016, Chinese State Administration of Taxation published the Advance Pricing Agreement (APA) Report of 2015. This report of 2015 contains statistics of APAs that China concluded from 2005 to 2015. China has concluded 6 bilateral and 6
See MoreIndia: Signs A further five unilateral advance pricing agreements
India's Central Board of Direct Taxes has entered into a further five unilateral advance pricing agreements (APAs). The APAs were signed on 27 October 2016 with Indian taxpayers operating in various sectors, including manufacturing and
See MoreGreece: Amendment to TP documentation rules and APAs
A Law naming ‘Law 4410/2016’ has been announced amendments on the Greek Tax Procedure Code, TP Documentation Rules and the legal framework for Advanced Pricing Agreements (APAs). Amendments on TP Documentation The first amendment mentions to the
See MoreHMRC Updated guidance on advance pricing agreements
On 8 November 2016, HM Revenue & Customs (HMRC) updated Statement of Practice 2 (2010) which sets out the process for obtaining advance pricing agreements (APAs). The updated statement of practice: Updates previous guidance on the
See MoreCroatia: Proposal for corporate income tax amendments
The Tax Administration has presented proposed changes to the Corporate Income Tax Law (CIT law) on 4th November 2016. The significant elements are summarized below: Tax Base The tax base of corporate income tax will be extended by introduction of
See MoreTurkey: Amendment in transfer pricing legislation
The Law No. 6728 on the amendment of certain laws for the improvement of the investment landscape has been published in the Official Gazette on 9 August 2016. This law amended certain transfer pricing provisions. Some of the provisions are given
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 MoreMexico: Government passes new transfer pricing rules for APA
The Mexican government recently passed a new regulation to permitting the Mexican Tax Authorities to perform on-site visits to carry out their own functional analysis as a part of the Advanced Pricing Agreement (APA) process. Rule 2.12.8 published
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