OECD: BEPS-related transfer pricing documentation, country-by-country reporting draft guidance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
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
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