Ukraine: 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 MorePortugal: Madeira’s International Business Center regime transfer pricing deadline
Among other tax incentives, the new Madeira International Business Centre (MIBC) regime introduced by Portugal provides reduced corporate income tax rates of 4% (in 2012) and 5% between 2013 and 2020. Under the new regime companies are required to
See MorePeru: Changes to transfer pricing documentation requirements
The Resolution 175-2013 of Peru sets out regulations concerning new transfer pricing documentation requirements which have become effective from 1 June 2013. According to the new rule taxpayers subject to the transfer pricing rules are required to
See MoreIndia: Documentation rules for transactions with “notified jurisdictional areas”
Section 94A to the Income Tax Act, 1961 empowers the Indian Government to blacklist certain jurisdictions which do not effectively exchange information with India. Those jurisdictions are classified as “notified jurisdictional areas.” The
See MoreHungary: New Decree on Transfer Pricing Documentation Rules
The Hungary’s Ministry of Finance has issued Decree 20/2013 on 18 June 2013. The decree clarified the transfer pricing documentation obligations of Hungary. The Decree 20/2013 is designed to decrease the taxpayers’ administrative burden and to
See MoreCzech Republic: New Decree on Low Value Adding Services
The General Financial Directorate (D-10) has issued the new Decree related to Low Value Adding Services took into effect on January 1, 2013 and it will relief qualifying taxpayers from preparation of full-phase transfer pricing documentation and
See MoreIndia: Transfer Pricing Reporting Requirements
Recently India’s Central Board of Direct Taxes issued guidance that expands the transfer pricing reporting requirements of certain international transactions and certain “specified domestic transactions.” To bring into line those reporting
See MoreHungary: Draft bill on the proposed changes to transfer pricing reporting obligations
The Ministry of National Economy of Hungary had announced a draft bill in March 2013. The draft bill proposed significant changes to the reporting requirements regarding the determination of arm’s length prices. According to the proposed changes
See MoreRussia: Offering New Transfer Pricing Deadlines
The Russian government has sent Draft Law No. 79859-6, which offers to set new transfer pricing deadlines for taxpayers for the second reading to the lower house of the Russian parliament. These changes may impact international businesses operating
See MoreHungary: Proposed Changes to Transfer Pricing Rules
The Ministry of National Economy (’the Ministry’) of Hungary has proposed changes to Hungarian transfer pricing documentation requirements. They have introduced provisions relating to low value added services and specified criteria for selection
See MorePoland – Reviewed tax haven list, transfer pricing documentation
Poland’s Ministry of Finance proposed to change the rule and regulation containing the list of countries and territories that are identified as applying “harmful tax competition on March 8 2013”. After finalizing the changes the Polish
See MorePhilippines: New Transfer Pricing Regulations
The Philippines’ Secretary of Finance issued Revenue Regulations (RR) No. 02-2013 – the transfer pricing regulations – on 23 January 2013, which became effective from 9 February 2013. The new regulations provide guidance in applying the
See MoreGreece: New Transfer Pricing Documentation Rules
The Greek Parliament passed Income Tax amendments in January 2013 which changes to the transfer pricing provisions have been included. In Greece’s income tax law Article 39 and 39A have been repealed by new measures. According to the amendments
See MoreIrish Revenue announces transfer pricing compliance monitoring approach
On 6 December 2012 it was published that the Irish Revenue released guidance on 26 November 2012 setting out how they are proposing to monitor transfer pricing compliance in accordance with Part 35A of the Taxes Consolidation Act 1997 The guidance
See MoreColombia: Transfer pricing documentation and APA requirements amended
It was reported on 29 August 2012 that, decree 1602, published in the Official Gazette of 27 July 2012, modifies some of the transfer pricing regulations established by Decree 4349 of 2004. Some of the most important modifications, applicable as
See MoreTransfer pricing gets intensive focus in Vietnam’s General Department of Taxation
During the late July 2011 Vietnam’s General Department of Taxation (GDT) and HCM tax authorities took several activities on transfer pricing (TP) which focused importantly on increasing awareness and strengthening the implementation of TP
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