Bulgaria: Information regarding Transfer Pricing Documentation
An Appendix 4 has been added to the return in accordance with commencing on the tax return for 2013, to be used by taxpayers to report related party transactions and transactions with entities situated in a jurisdiction with a preferential tax
See MoreNigeria – Companies requested to submit group transfer pricing documentation
In Nigeria the tax authority FIRS is asking taxpayers to send in transfer pricing documentation for the group to which they belong. Although there is no specific deadline they should do so as soon as possible and the documentation should be with the
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 MoreEU: JTPF presents comments received on the discussion paper on the Arbitration Convention
The Joint Transfer Pricing Forum (JTPF) held a meeting in Brussels on 6 March 2014at which the following items were discussed: – Information by the European Commission on ongoing issues; and – Arbitration
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 MoreOECD releases paper on transfer pricing documentation
On 30 January 2014, as part of the action plan on base erosion and profit shifting, the OECD published a discussion draft on transfer pricing documentation. This discussion draft takes the form of a revised Chapter V of the OECD Transfer Pricing
See MoreOECD: BEPS-related transfer pricing documentation, country-by-country reporting draft guidance
On 31 January 2014 the Organization for Economic Co-operation and Development (OECD) released an initial draft of revised guidance on transfer pricing documentation and country-by-country reporting. This is related to Action 13 under the Base
See MoreAustralia: ATO dispatched International Structuring, Profit Shifting field Program
The Australian Taxation Office (ATO) in accordance with current base erosion and profit shifting (BEPS) activities dispatched an “international structuring and profit shifting” (ISAPS) field review program. This is a decentralized national
See MoreFrance – “Abridged” transfer pricing documentation to be filed annually
On 12 December 2013 it was reported that recently enacted transfer pricing legislation includes a new requirement for large taxpayers to file annually an “abridged” version of their transfer pricing documentation. The requirement to file the
See MoreFrance – Additional reporting requirements for companies
The national assembly of France passed a legislation related to reporting requirements on 5 November 2013. The legislation consists of new reporting requirements in addition to transfer pricing documentation for companies. Companies which will fall
See MoreOECD publishes comments on white paper on transfer pricing documentation
The OECD has published comments received on the White Paper on transfer pricing documentation issued on 30 July 2013. The comments received from more than forty commentators are to be discussed by Working Party No. 6 of the OECD’s Committee on
See MoreUkraine: New transfer pricing rules
A law “On the Amendments to the Tax Code of Ukraine Regarding Transfer Pricing” passed its second and final reading on 4 July 2013 and was adopted by the Ukrainian Parliament. This legislation will become effective from 1 September
See MoreRussia- Clarification on documentation to verify appropriate transfer pricing method
The Ministry of Finance of Russia has issued public letter No. 03-01-18/26965 in relation to transfer pricing documentation on July 11, 2013 that clarifies process for preparing and submitting transfer pricing documentation for a particular
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 MoreFrance: Greater transfer pricing documentation burden on taxpayers
The government of France has introduced a new bill with an effort to prevent tax evasion. The bill is expected to bring a greater compliance burden to taxpayers. According to the draft law companies are required to submit and file their
See MoreFrance is looking to review transfer pricing provisions
A report published by the Inspectorate General for Finance (IGF) on 6 June indicates that France is looking to review transfer pricing aspects of its tax code in order to better impose the arm’s-length principle. The French sanctions and
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 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
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