Canada: 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
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
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