India: High Court Rules on Use of Multiple Year Data and High-Profit Comparables
Recently, the High Court (HC) issued its decision in the transfer pricing case of Chrys Capital Investment Advisors (India) Pvt. Ltd v. DCIT (ITA No. 417 of 2014) on the usage of multiple year data and high-profit comparables on 27 April 2015. The
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 transactions
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
See MoreOECD – Transfer pricing comparability data and developing countries
The OECD has prepared a paper in respect of transfer pricing comparability data and its use in developing countries. This is intended to find a response to concerns about the quality of comparable data available in developing countries. The lack of
See MoreColombia: Information regarding comparable data range and segmented data uses
In accordance with the Regulatory Decree 3030 of December 2013, there is an economic link between the parties if the transaction is between a branch and home office, a transaction involving a permanent establishments, a related party transaction
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