The Netherlands -Draft law implementing new transfer pricing documentation requirements
The Dutch State Secretary of Finance released a draft law providing changes to the Dutch Corporate Income Tax Act 1969 on 15 September 2015. The proposed changes involve supplementary transfer pricing documentation requirements in line with the
See MoreRomania enacts new Fiscal Procedure Code
The Romanian tax authority has published the revised Fiscal Procedure Code in the Official Gazette no. 545 dated 23 July 2015. The existing Fiscal Procedure Code is being updated by Law 207/2015 implementing new provisions with respect to tax
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 MoreUkraine: President sigend the law on amendments to transfer pricing regulations
President of Ukraine has signed the Law No. 609-VIII on 7 August 2015 regarding Amendments to the Tax Code of Ukraine (in respect of transfer pricing)" (the Law). The Law was officially published on August 10, 2015, and came into force from August
See MoreKorea: Draft law for implementing BEPS-related transfer pricing requirements
The Ministry of Strategy and Finance of South Korea has released draft legislation for amending existing provisions of Korean law. The draft legislation generally follows Action 13 of the OECD/ G20 project on base erosion and profit shifting
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 MoreAustralia: Stronger penalties to fight against multinational tax avoidance
The Government of Australia announced double the maximum administrative penalties that can be applied by the Commissioner of Taxation to large companies that enter into tax avoidance and profit shifting schemes. The increased penalties, under
See MoreAustralia: New transfer pricing documentation standards
On 6 August 2015, the Australian Treasury released exposure draft law to implement reporting requirements for large multinational businesses in line with recommendations by the OECD and G20. In the 2015-16 Budget, the Australian government announced
See MoreUS Treasury to develop regulations implementing CbC reporting requirement
US Treasury announced on 31 July 2015 that the US government intends to develop regulations implementing the OECD/G20 base erosion and profit shifting (BEPS) action plan guidance on country-by-country (CbC) reporting by multinational
See MoreUkraine: State Fiscal Service published letter regarding tax control over transfer pricing
The State Fiscal Service (SFS) published Letter No. 24525/7/99-99-22-01-02-17 issued on 7 July 2015 addressing the penalties levied for failure to submit transfer pricing (TP) documentation or to include relevant information about controlled
See MoreSpain: BEPS country by country reporting provisions enacted
The Spanish Ministry of Finance published Royal Decree 634/2015 of 10 July 2015 in the Official Gazette on 11 July, 2015. The Decree contains corporate income tax regulations including (BEPS) country by country reporting requirements in line
See MoreGreece: tax authorities issue circular to clarify transfer pricing regulations
The Greek tax authorities issued circular no. POL 1142/02.07.2015 dated July 2, 2015 to explain transfer pricing (TP) documentation issues raised in light of the new Income Tax Law no. L. 4172/2013 and Tax Procedures Code no. L. 4174/2013. The
See MoreGermany plans to adopt BEPS guidance on transfer pricing documentation and CbC reporting requirement
The German government has announced plans to incorporate guidance on transfer pricing documentation and country-by-country (CbC) reporting) in line with the OECD’s Base Erosion and Profit Shifting (BEPS) project into local legislation. The
See MorePoland: Published revised draft bill on transfer pricing documentation
Poland’s Government published the revised draft of the Personal Income Tax /Corporate Income Tax Act (Bill) concerning documentation of intercompany transactions on 18 June 2015. According to the revised draft, the management or control
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 MoreSlovak Republic: New transfer pricing documentation guidance
The Finance Ministry has issued new guidance on transfer pricing documentation. This guidance creates three categories of documentation based on the degree of detail of the information required in relation to a taxpayer’s risk profile. The
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 More