OECD: Transfer pricing documentation – Country by Country Reporting
Action 13 of the action plan on Base Erosion and Profit Shifting (BEPS) is concerned with supplying the tax administration with sufficient information to allow them to assess transfer pricing risk. The guidance issued by the OECD in September 2014
See MoreIceland: Released draft regulation on transfer pricing documentation
The Icelandic Ministry of Finance released the draft regulation on transfer pricing on 13 October 2014. According to the draft regulation outlining detailed transfer pricing rules was released on 13 October 2014 and when finalized this will apply
See MoreSlovak Republic: New guidance regarding transfer pricing documentation has been published
The Ministry of Finance has published new guidance on the contents of transfer pricing documentation (TPD) on August 20, 2014 that requires changes for most taxpayers. This alert summarizes the transfer pricing legislative developments as well as
See MoreSingapore: IRAS invites to comments on transfer pricing documentation requirements
The Inland Revenue Authority of Singapore (“IRAS”) invited comments by 24 September 2014 on its proposed update to Section 4 of the existing Singapore Transfer Pricing Guidelines relating to the transfer pricing documentation, which was first
See MoreCzech Republic: Documentation requirement for tax payer
From 1 January 2014 Czech taxpayers must send in a separate disclosure form entitled Overview of Transactions with Related Parties at the time of filing the corporate tax return. This applies to taxpayers with foreign related party transactions in
See MoreSpain: Supreme Court rules certain provisions of the transfer pricing regulations
The Spanish Supreme Court issued its final judgment regarding challenges the constitutionality of specific provisions of the transfer pricing regulations on 14 July, 2014. The Supreme Court focused the following areas; Secondary adjustment: The
See MoreFrance- Deadline for filing additional Transfer Pricing Statement
The French Government adopted a new additional transfer pricing documentation requirement codified under Article 223 quinquies B of the French General Tax Code. According to the new rule certain taxpayers will be able to file a “reduced”
See MoreSlovak Republic: New improvements in Transfer Pricing
The Financial Directorate in Slovak Republic has issued a methodological guideline on the application of transfer pricing methods. According to the changes to the OECD Transfer Pricing Guidelines in July 2010, the amendment to the ITA has abolished
See MoreCanada: CRA publishes “PTM-05R” on requests for contemporaneous documentation
The Canada Revenue Agency (CRA) has issued a memo on transfer pricing on applications for contemporaneous documentation of the auditor entitled “PTM-05R” on March 28, 2014 and it replaces preceding PTM on the same subject dated 13 October 2004.
See MoreGreece: Guidance for transfer pricing documentation requirements
On 9 April 2014, the Minister of Finance of Greece issued a ministerial decision that provides guidance regarding the following transfer pricing documentation requirements: The ministerial decision set out the detailed requirements in respect of the
See MoreCanada: New guidance regarding contemporaneous documentation
The CRA’s updated Transfer Pricing Memorandum (TPM-05R) clarifies the CRA’s process for requesting contemporaneous documentation and includes specifically four new sections, such as method of delivery, three-month delivery, documents provided to
See MoreCanada follows suit with US and excludes references to OECD in TP request
Canada has adopted similar position to the US and has excluded references to the OECD’s three-tier documentation in favour of its own country specific transfer pricing (TP) documentation. The Canada Revenue Agency (CRA) has reviewed its TP
See MoreMalaysia – Transfer pricing documentation required for 2014 tax return
The Malaysian transfer pricing rules imposing the arm’s length principle are contained in section 140A of the Income Tax Act. The Inland Revenue Board has been increasing its scrutiny of the transfer pricing issues of large taxpayers and is
See MoreUK – Tougher Penalties for Offshore Evaders
Offshore tax evaders are likely to face stiffer penalties under measures recently announced in the 2014 UK Budget. The UK government has said that stricter penalties would apply to individuals who hold money in hidden bank accounts in countries that
See MoreOECD – Transfer pricing documentation and country-by-country reporting consultation
The OECD is holding a consultation on 19 May 2014 to consider transfer pricing documentation and country-by-country reporting. This follows the publication of a discussion draft in relation to the BEPS (base erosion and profiting shifting) Action
See MoreBelgium – Tax Penalties for Non-Compliance ranging 10% to 200%
Belgium is determined to enforce tax penalties to ensure that taxpayers submit their latest tax returns on time. The Finance Ministry has encouraged taxpayers to send in a complete and correct income tax declaration for 2013, to avoid incurring a
See MoreBulgaria: 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
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