Korea: MOEF proposes Tax Revision Bill 2021
On 26 July 2021, South Korea’s Ministry of Economy and Finance (MOEF) has issued an overview of the proposed Tax Revision Bill 2021 to support new industries and employment, as well as inclusive growth. The Tax Revision Bill 2021 includes 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 MoreVietnam: MoF issues new transfer pricing Decree
On 5 November 2020, the Vietnamese Ministry of Finance (MoF) has issued new transfer pricing Decree No. 132/2020/ND-CP. The new Decree replaces the existing Transfer Pricing (TP) regulations (Decree No. 20/2017/ND-CP) and provides the following new
See MoreTaiwan: MOF announces draft amendments to transfer pricing guidelines
On 18 August 2020, Taiwan’s Ministry of Finance (MOF) has announced draft amendments to certain transfer pricing provisions based on chapter 6 of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The
See MoreBelgium: TP Circular on OECD guidelines
On 25 February 2020, the Belgian tax authorities published the final version of the transfer pricing (TP) Circular No. 2020/C/35 in French on their website on transfer pricing guidelines for multinational enterprises and tax
See MoreIndia: ITAT decision on criteria for selecting transfer pricing comparable companies
The Kolkata Bench of the Income Tax Appellate Tribunal (ITAT) in the case of: Philips Medical Systems (P.) Ltd. v. ITO, held that an entity engaged in both manufacturing and trading activities cannot be a comparable company for benchmarking the
See MoreUS: IRS files pre-trial memorandum against Coca Cola in transfer pricing dispute
On 15 February 2018 the IRS filed a pre-trial memorandum against The Coca Cola Company on the grounds that the transfer pricing methods used by Coca Cola were not in compliance with the arm’s length standard under section 482. The case relates to
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