Australia: Administrative Review Tribunal rules in favour of Alcoa against ATO in key transfer pricing ruling
This case focused on a major transfer pricing issue, where ATO claimed Alcoa underpriced its alumina sales to Aluminium Bahrain B.S.C. (Alba) from 1993 to 2009, causing a tax shortfall of over AUD 213 million. Australia’s Administrative Review
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Spain: National Court issues rule on TP adjustment using median of arm’s length range
On 29 July 2023, the Spanish National Court issued a decision that provided clarification on the range of arm's length pricing adjustments applicable. In this case, Ferroli Spain, a Spanish manufacturer specializing in non-electric stoves,
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Malaysia: IRBM publishes transfer pricing rules 2023
On 29 May 2023, the Malaysian Inland Revenue Board of Revenue (IRBM) officially published Order No P.U. (A) 165 (TP Rules 2023) introducing a new transfer pricing documentation process effective from assessment year 2023 onwards. The main changes
See MoreIndia issues notification on transfer pricing tolerance range for 2019–20
On 19 October 2020, India’s Central Board of Direct Taxes has released the Notification No. 83/2020 setting the arm’s length pricing variation limit for assessment year 2020-21. Accordingly, the variation between the arm’s length price
See MoreIndia: CBDT issues Notification on transfer pricing arm’s length tolerance range
On 13 September 2019, the Central Board of Direct Taxes (CBDT) published Notification No. 64/2019, which sets a tolerance range for the variation between the arm’s length price and the transaction price for the 2019-20 assessment year. The
See MorePanama: TP documentation requirements and Arm’s length principle
Decree 390 was published in the Official Gazette on 25 October 2016 to regulate the arm’s length principle established in the Fiscal Code and establishes Transfer Pricing documentation requirements. The Decree will enter into force on 1 January
See MoreIndia: High Court Decision on Transfer Pricing Comparability
The High Court of Bombay issued its decision in the case of: CIT v. Garware Polyester Ltd on 23 June 2015. The decision concerns a situation where the scope of work accepted by the associated enterprise (AE) agent is wider than that of a comparable
See MoreGreece: tax authorities issue circular to clarify transfer pricing regulations
The Greek tax authorities issued circular no. POL 1142/02.07.2015 dated July 2, 2015 to explain transfer pricing (TP) documentation issues raised in light of the new Income Tax Law no. L. 4172/2013 and Tax Procedures Code no. L. 4174/2013. The
See MoreTaiwan – Separate analysis for certain controlled transactionsÂ
Taiwan’s Ministry of Finance issued guidance that relaxes the rules requiring a separate analysis for controlled transactions. Under the transfer pricing safe harbor rules (from 2008), a profit-seeking enterprise is required to prepare a transfer
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