Malta seeks comments on draft Transfer Pricing Rules

December 29, 2021

On 22 December 2021, Malta’s Commissioner for Revenue (CFR) has published draft Transfer Pricing Rules on its website for public consultation. The consultation period will end on 28 February 2022, and the draft Transfer Pricing Rules shall come

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Ukraine: Cabinet of Ministers adopts new APA procedures

November 04, 2021

On 28 October 2021, the Cabinet of Ministers of Ukraine has adopted new procedures of preliminary coordination of advance pricing agreements (APAs) in controlled transactions, as a result of which agreements on preliminary coordination of pricing,

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China publishes simplified procedures for unilateral APAs

August 06, 2021

On 26 July 2021, the State Administration of Taxation (SAT) issued Announcement No. 24 (2021) that finalizes a simplified procedure for unilateral advance pricing arrangements (APAs), which will come into effect on 1 September 2021. An

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Indonesia publishes new regulations concerning advance pricing agreements

April 02, 2020

On 18 March 2020, the Indonesian Ministry of Finance released 22/PMK.03/2020 which updates the Advance Pricing Agreements (“APA”) regulations. The new regulations, effective 18 March 2020, include the following amendments: Previously

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India: CBDT signs first APA renewal

October 31, 2018

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

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India: CBDT publishes second APA annual report

September 05, 2018

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

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Canada: CRA publishes 2017 APA Program Report

July 17, 2018

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.

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India: CBDT signs seven more unilateral APAs

March 08, 2018

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

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Argentina: Government reforms transfer pricing rules via Decree 1112/2017

January 07, 2018

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

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Turkey: Revenue Administration publishes draft Communiqué 3 on APAs

October 25, 2017

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

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Morocco: New procedures for APAs

September 10, 2017

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

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Turkey: Announcement of unilateral APA signed

March 21, 2017

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.

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India: Signs A further five unilateral advance pricing agreements

November 29, 2016

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

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Ukraine: Cabinet of Ministers adopts new advance pricing agreement procedures

August 01, 2015

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

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Korea: Unilateral APA program introduced

December 22, 2014

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

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