France-New threshold for eligibility of abridged transfer pricing documentation
In France, a new law had been enacted on 8 November 2016 which provides for a reduced threshold for taxpayers to be eligible for filing the “abridged” transfer pricing documentation (Form 2257). The threshold as codified at Article 223 quinquies
See MoreUkraine: Revises its Transfer Pricing Legislation
Ukraine has introduced changes to the Tax Code regarding transfer pricing. It was officially published on August 10, 2015, and came into force from August 11, 2015. As per the new law which came into force from August 11 2015, taxpayers are
See MoreColombia- Tax haven transactions subject to transfer pricing regime
The National Tax Authority of Colombia published Ruling 20776 of 2015 according to which transactions carried out with tax haven jurisdictions in tax year 2014 are subject to the transfer pricing regime. According to article 260-7 of the Tax Code
See MoreEcuador-new regulations on transfer pricing documentation requirements
Recently Ecuador’s Internal Revenue Service (IRS) has issued regulations giving outlines to new transfer pricing documentation requirements. The new regulations require taxpayers to include substantial information on the economic substance of
See MorePoland: Draft Regulation Introducing Amendments Based on BEPS Documentation Requirements
The Polish Ministry of Finance published a draft regulation on 27 April 2015 which introduced amendments on transfer pricing documentation in line with the requirements of the OECD/G20 action plan on base erosion and profit shifting
See MoreColombia: Updates on documentation threshold’s, audit penalty and APA
According to the Regulatory Decree 3030 of December 2013, transactions over 32,000 UVT by type of transaction are subject to transfer pricing analysis only if the total amount of the transactions exceeds 61,000 TVU. In the case of transactions with
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
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