Colombia: CUP method valid for commodity transactions without quoted prices
The Colombian Tax Authority (DIAN) released Ruling 1118 (Int. 81) of 13 February 2024, which provides clarification of the application of the Comparable Uncontrolled Price (CUP) method for commodity transactions between related parties that do not
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Poland releases notice providing clarification on TPD documentation
On 4 September 2023, the Polish Official Gazetted a notice aimed at providing comprehensive clarification regarding the regulations governing transfer pricing documentation for corporate income tax purposes. This notice encompasses several key
See MoreRussia: FTS clarifies the application of transfer pricing control under sanctions
On 14 March 2022, the Federal Tax Service (FTS) published guidance (Letter No. ШЮ-4-13/2724) stipulating that the application of sanctions against Russian individuals and legal entities may adversely affect the economic conditions of the
See MoreMexico: Congress approves Economic Package for the fiscal year 2022
On 26 October 2021, Mexican Congress has approved the tax reform for 2020 which was presented for the fiscal year 2022 which was presented on 8 September 2021. The Economic Package clarifies income tax law, value-added tax (VAT) law, excise tax
See MoreJordan introduces transfer pricing rules for MNE groups
On 7 June 2021, the Hashemite Kingdom of Jordan has published Regulation No. 40 of 2021 in the Official Gazette. The Regulation has introduced transfer pricing rules for multinational entity (MNE) groups with effect from 7 July 2021. The Regulation
See MorePeru: SUNAT issues guidance on comparability analysis using multi-year data
On 29 April 2021, the Peruvian tax authorities (SUNAT) has issued Administrative Guidance No. 036-2021-SUNAT/7T0000 providing guidance in relation to the use of multi-year data in determining arm's length transfer pricing. The guideline provides
See MoreGreece: AADE publishes a guide regarding the COVID-19 effects on TP issues
On 10 March 2021, the Greek Public Revenue Authority (AADE) published Circular Ε. 2054 of 10 March 2021, providing general guidance of how to deal with the adverse effects of the COVID-19 pandemic on transfer pricing issues. The guidance is
See MoreDominican Republic: DGII declares public consultation to amend TP rules
On 1 March 2021, the Directorate General of Internal Revenue (DGII) made an announcement of launching a public consultation on the draft modification of articles 5, 7, 10 and 18 of the transfer pricing (TP) regulation, established by means of the
See MoreParaguay introduces new guidance on TP law
On 30 December 2020, the tax authority of Paraguay issued Decree 4644/2020, providing further guidance on the technical aspects of Paraguay’s transfer pricing (TP) provisions included in Law 6380. Law No. 6,380/2019 modernized the Paraguayan
See MoreTaiwan: MOF amends transfer pricing provisions for profit-seeking enterprises
On 28 December 2020, Taiwan’s Ministry of Finance (MOF) has announced amendments to certain transfer pricing provisions based on chapter 8 to 10 of the OECD Transfer Pricing Guidelines for profit-seeking enterprises. The key amendments are
See MoreThailand publishes new transfer pricing regulation
On 6 November 2020, Mr. Apisak Tantivorawong, the Minister of Finance issued Ministerial Regulation No. 369, published in the official bulletin 2556. The regulation sets basic rules to be followed by the tax authority when evaluating transactions
See MoreOECD: Tax Talk Summarises Latest Tax Developments
In a Tax Talk on 12 October 2020 the OECD gave an update of recent developments. Digital Economy The OECD’s Inclusive Framework met on 8 and 9 October 2020 and Blueprint reports on Pillar 1 and Pillar 2 of the proposals on taxation of the
See MoreTanzania: Government issues new Transfer Pricing Regulations 2018
On April 27, 2018,Government has published new Income Tax (Transfer Pricing) Regulations of 2018. The regulations have issued on November 2018, which replaces the Income Tax(Transfer Pricing) Regulations 2014. This provides extra requirements
See MoreBelgium issues draft TP guidelines for public comments
The tax authority of Belgium has published a draft Circular on the 2017 update to the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing (TP) Guidelines. On 9 November 2018, the draft Circular was published by the Belgian
See MoreFinland: Tax administration issued guidelines on the allocation of profits to PE
On 30 April 2018, the tax administration published a guideline no.A72/200/2018 on profit distribution for a permanent establishment (PE). The guidelines clarify that, upon request, a foreign company has to specify how it has allocated profits to a
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