US: IRS publishes FAQs on transfer pricing documentation best practices
On 14 April 2020, the United States (US) Internal Revenue Service (IRS) has posted on its website new frequently asked questions (FAQs) outlining best practices and common error in preparing transfer pricing documentation. The IRS states that
See MoreSweden:Tax Authority declares on the relevance of the TP documentation when filing an incorrect tax return
On 3 December 2018, the tax authority issued Declaration No. 202 251680-18 / 111, on the relevance of Transfer Pricing documentation in the event of a tax surcharge for providing incorrect information. If the company has made an inaccurate task
See MorePoland: President signed an act including amendment of TP measures effective in 2019
On 14 November 2018, President of Poland signed an act including amendment of transfer pricing measures effective in 2019. The new laws repeal the Article 9a of the CIT Act regarding transfer pricing, which is being replaced by Chapter 1a,
See MorePoland: Parliament passes tax reform bill for 2019 including MDR
On 26 October 2018, the upper house of the Polish Parliament (the Senate) adopted the draft bill introducing far-reaching changes to the Polish tax law, including European Union (EU) Mandatory Disclosure Rules (MDR). The main difference of the
See MoreFrance: Change in Transfer Pricing Documentation Requirements
French Parliament updated their transfer pricing documentation rules. Under the Finance Act for 2018, which was approved by the Parliament on 21 December 2017, French companies must submit the transfer pricing documentation for financial years
See MoreThailand: Cabinet approves draft Transfer Pricing Act
On 3 January 2018, the Thai Cabinet approved the draft transfer pricing act following a public hearing held in July 2017 on the first draft Act that was approved in principle in May 2015. Subject to a legislative procedure and announcement, the
See MoreZambia: MoF approves amendments in transfer pricing regulation
The Minister of Finance (MoF) is set to approve changes in transfer pricing rules, including procedures for the valuation of the transfer pricing transactions between related entities and allow for taxable income adjustments and documentation
See MoreSingapore: Income Tax (Amendment) Bill 2017 approved
The Income Tax (Amendment) Bill 2017 was approved by the Singaporean lawmakers on 2 October 2017.The amendments to the Income Tax Act comprise of tax changes announced in the 2017 Budget. According to the approved Bill existing corporate income tax
See MoreSingapore: draft transfer pricing legislation proposed
According to the draft Income Tax (Amendment) Bill 2017 (Draft Bill) proposed on 19 June 2017, section 34D of the Singapore Income Tax Act (SITA) would be expanded to provide clarification on the meaning of arm’s-length conditions. The proposed
See MoreUruguay- New transfer pricing requirements for corporations with income derived from tax-exempt activities
The Tax Authority of Uruguay issued Ruling No. 5,947 on 6 December 2016 according to which a corporation conducts business with foreign related companies with income derived from a tax-exempt activity will be subject to the transfer pricing
See MoreSouth Africa: SARS published Transfer Pricing documentation proposal for public comments
The South African tax authorities published for public comments a Draft Notice on additional Transfer Pricing record-keeping requirements. Where a person has entered into a potentially affected transaction, the aggregate of the transaction for the
See MoreTanzanian Requires Taxpayers with Related-Party Transactions Contemporaneous Transfer Pricing Documentation
The requirement for transfer pricing documentation has been in place since February 7, 2014 but the Tanzania Revenue Authority (TRA) had not previously enforced this requirement. TRA have started requesting transfer pricing documentation from
See MoreFrance-Approved Finance Bill 2016 and amended Finance Bill 2015
The French Parliament approved the Finance Bill for 2016 and and the amended Finance Bill for 2015 on 17 December 2015. The Finance Bill enacts the country-by-country (CbC) reporting requirement into the legislation of France. From 1 January 2016
See MoreGreece: Public Revenue Authority Published Clarification on Transactions of Real Estate Companies and Comparables
Public Revenue Authority of Greece published clarification on transactions of real estate companies and comparables data. The Public Revenue Authority issued document ΔΕΑΦΒ 1136663 ΕΞ 2015/21.10.2015 to clarify that the transfer pricing
See MoreChina: SAT is Seeking Public Comments on Consultation Draft for Implementing Special Tax Adjustments
On 17 September 2015, China’s State Administration of Taxation released a consultation draft circular concerning implementation measures for special tax adjustments that would replace the existing Guoshuifa No. 2 (Circular 2). Now the SAT is
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 MoreThailand: Draft Act contains new transfer pricing provisions
The Cabinet of Thailand approved a draft Act on Revenue Code Amendment on 7 May 2015. If enacted the Act would introduce specific transfer pricing provisions into the Revenue Code and also would amend the tax law of Thailand to apply transfer
See MoreFrance: Tax Administration Publishes Guidelines On The Abridged Transfer Pricing Documentation
French tax administration published guidelines on the abridged transfer pricing documentation in the Official Bulletin for Public Finances Taxes on 6 November 2014. Legal persons established in France must be submitted in the French language to the
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