France: New article on transfer pricing assessments and withholding tax relief for repatriated profits
A new Article L. 62 A of the French tax procedure code was published in the official bulletin on 2 September 2015. The article provided rules that efficiently establish the tax treatment of certain profits transferred abroad by French taxpayers, and
See MoreSri Lanka: Commissioner General of Inland Revenue publishes gazette on Transfer Pricing Regulations
The Commissioner General of Inland Revenue has published gazette no. 1907/26 dated 25 March 2015 on Transfer Pricing Regulations. It was made available on the Government Printer’s website on 27 May 2015. The gazette requires the taxpayer to
See MoreBangladesh: Changes in Transfer Pricing Provisions in Finance Bill 2015 Passed by Parliament
The Bangladesh Parliament passed the Finance Bill 2015 on June 29, 2015 with some changes in the transfer pricing provisions. The legislation relating to the report from an accountant required to be furnished by a person who has entered into
See MoreChina issues Circular Caishui [2014] No. 59 to extend the current preferential corporate income tax treatment
China’s Ministry of Finance, the State Administration of Taxation, Ministry of Commerce, Ministry of Science and Technology and National Development and Reform Commission jointly issued Circular Cai Shui no 59 On 8 October 2014, has extended the
See MoreSouth Africa: Revised Corporate Tax Returns Reflect REIT Reporting Requirements
The South Africa Revenue Service announced changes to the income tax return (ITR14) in respect of the 2014 year of assessment, to reflect rules for identifying a real estate investment trust (REIT). The changes are as follows; For the
See MoreArgentina: New decree creates for monitoring transfer pricing rules
Tax Authority has published Decree 2103/2014 on 17 November 2014, in order to created a special unit to monitor cross-border trade and coordinate the work of the various government bodies to ensure the correct application of the law on international
See MoreInformation regarding Transfer pricing reporting requirements in Czech Republic
The General Tax Directorate has released information regarding the new transfer pricing reporting requirements on its website and confirms that tax audits, the tax authorities will pay special attention to transactions with related parties and the
See MoreCzech Republic: Issues transfer pricing form
From October 2014 a transfer pricing form has been introduced for submission to the tax authorities annually with the tax return, requiring information on related party transactions. This form must be submitted by taxpayers if their total assets are
See MoreMalaysia: Inclusion of the new check-the-box requirements and its consequences
A new check-the-box named “Box R4” has been inserted on the 2014 tax return form (Form C) of Malaysia to declare by the corporate taxpayer for the confirmation that the preparation of contemporaneous transfer pricing documentation is complied in
See MoreMalaysia: increasing scrutiny of transfer pricing
The transfer pricing landscape in Malaysia continues to develop with the Malaysian tax authority becoming increasingly proactive and vigilant in examining the controlled transactions of multinational enterprises (MNEs). The intensity of tax audits
See MoreTurkey: Specific Transfer Pricing Compliance
An annual transfer pricing report must be prepared by the date of the annual tax return. The transfer pricing rules also specify documentation that must be maintained. Listed companies may also be required to submit a report on controlled
See MoreNigeria establish TP Division and disclose TP forms
Transfer Pricing Division will be accountable for the implementation and administration of the Income Tax Transfer Pricing Regulations No.1 2012 (TP Regulations) and it has build by the Nigeria’s Federal Inland Revenue Service (FIRS). The TP
See MoreNigeria – New TP forms and established tax office
Nigeria’s Federal Inland Revenue Service (FIRS) has published a transfer pricing declaration and disclosure form for executing the transfer pricing regulations issued in 2012 and has established a tax office within the tax administration
See MoreHungary: amendment to transfer pricing documentation rules
The Ministry of Finance of Hungary issued an amendment of Decree No. 22/2009 related to transfer pricing documentation requirements. The amendment effectively increases the validity of an APA to 6 years. Under the new rules taxpayers recharging the
See MoreUkraine: penalty for failure to submit a controlled transaction report
From 1st September 2013, under the new transfer pricing law introduced in Ukraine, certain transactions between related and unrelated parties will be subject to the arm’s length principle and will be treated as controlled transactions under the
See MoreChile: New Transfer Pricing Compliance Requirement
A new transfer pricing compliance requirement has been introduced in Chile by Resolution No. 14 of 2013. According to the new rule Chilean taxpayers are required to file a Transfer Pricing Annual Informative Return (‘TP Return’) for calendar
See MoreNew transfer pricing form issued by Malaysia’s tax authority
Malaysia’s Inland Revenue Board (IRB) has issued a new form to collect information on transfer pricing compliance, and enforce transfer pricing rules for the corporate taxpayers. The IRB targeted the corporate taxpayers because they have
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