Canada: 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See MoreTurkey: Draft guidance on APA applications
The Turkish revenue administration released draft guidance in early April 2015 on advance pricing agreements (APAs).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
See MoreSlovenia: APA concluded for transfer pricing purposes
On 1 August 2014, the amendments to the Financial Administration Law (the Law) entered into force. According to the law, the Tax Procedure Act effective from 2007 introduced a system of tax rulings and from 1 August 2014 advance pricing agreements
See MoreSlovenia: Financial administration approved to conclude advance pricing agreements
In Slovenia, the amendments to the Financial Administration Law (the Law) entered into force on 1st August 2014. This Law Based on financial authorities is authorized to conclude advance pricing agreements (APA) for transfer pricing purposes. The
See MoreIndia: Amended the transfer pricing rules in budget 2014
On 10 July 2014, the Finance Minister proposes amendments to India’s transfer pricing rules in India’s budget of 2014. The Budget 2014 proposes to amend the rules to provide that an APA entered into with regard to a future transaction may also
See MorePhilippines- 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 More