OECD: Consultation Document on Transfer Pricing for Minerals
On 10 May 2023 the OECD published a consultation document with the title Determining the price of minerals: A Transfer Pricing Framework. This is a draft toolkit to support developing countries in combating base erosion and profit shifting relating
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Cyprus: Tax department issues additional FAQs on TPD rules
On 14 March 2023, the Tax Department of Cyprus has issued three additional questions to its Frequently Asked Questions (FAQs) section, with respect to transfer pricing. The additional questions are summarized below: How is the EUR 750,000
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Singapore: IRAS updates TP Guidelines on indicative margin for related-party loans
On 3 January 2023, the Inland Revenue Authority of Singapore (IRAS) published updated transfer pricing (TP) guidelines on indicative margin for related-party loans. IRAS publishes the indicative margin at the beginning of each calendar year. The
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Netherlands publishes new transfer pricing decree
On 1 July 2022, the Netherlands Ministry of Finance issued Decree No. 2022-0000139020 related to the application of the arm's length principle and the OECD transfer pricing guidelines. The New Decree replaces the previous transfer pricing (TP)
See MoreCyprus: Tax department issues a new FAQs section on transfer pricing
On 24 January 2022, the Cyprus Tax Department published a new “Frequently Asked Questions (FAQs)” section on its website on Transfer Pricing (TP). The FAQs relate to the Interpretative Circular 3 issued on 30 June 2017 (Back-to-Back Circular).
See MoreCroatia: Finance Ministry decides new interest rate between related parties
The Ministry of Finance announced a new interest rate of 2.68% on loans between related parties for 2022 before the beginning of the tax period in which it is applied. This means that interest is calculated at the rate of 2.68% of the minimum
See MoreRussia: MOF publish clarification guidance for TP purposes
On 18 November  2021, the Russian Ministry of Finance (MoF) published a Guidance Letter No. 03-03-07/85525 clarifying  that a loan is considered a controlled debt for Transfer Pricing (TP) purposes if it is granted to a Russian company by a third
See MoreCroatia: Government fixes related party interest rate for 2021
The Croatian Government has changed the arm’s length interest rate from 3.42% per annum to 3% per annum regarding loans between related parties for the year 2021. This rate is effective from 1st January 2021 and applies for loans between resident
See MoreAustralia: ATO concerns over mischaracterized financial arrangements
On 25 May 2020, the Australian Taxation Office (ATO) issued Taxpayer Alert (TA) 2020/2, in relation to mischaracterised arrangements and schemes connected with direct foreign investment into Australian businesses. ATO is concerned that
See MoreSweden: Tax agency implements the OECD principles on financial transactions
On 24 April 2020, the Swedish tax agency has updated the financial transaction page. In February 2020, the OECD published a new Chapter X of the guidelines on financial transactions. Financial transactions between companies within a group are
See MoreAustralia updates guideline for simplified transfer pricing record keeping options
On 11 September 2019, the Australian Taxation Office (ATO) released an updated version of Practical Compliance Guideline (PCG) 2017/2 concerning the eligibility criteria for applying simplified transfer pricing record keeping options for
See MoreAustralia: ATO compliance approach to the arm’s length debt test
On 28 August 2019, the Australian Taxation Office (ATO) published draft Practical Compliance Guideline PCG 2019/D3, which sets out the proposed compliance approach for the use of the arm’s-length debt test (ALDT) for the purposes of
See MoreAustralia issues draft ruling on thin capitalization
On 5 April 2019, the Australian Taxation Office (ATO) released a draft ruling TR 2019/D2 with respect to the requirements for the application of the arm’s-length debt test (ALDT) in the thin capitalization rules. The draft ruling proposes that
See MoreAustralia: Improving the integrity of the thin capitalization rules
The Australian Government announced that it will implement two changes to improve the integrity of Australia’s thin capitalization rules in the 2018-19 Budget. The changes are: requiring entities to align the value of their assets for thin
See MoreIreland publishes tax and duty manual on loans applied in acquiring an interest in a company
On 16 July 2018, Irish revenue authority published a Tax and Duty Manual concerning loans applied in acquiring an interest in a company. The contents of Tax and Duty Manual Part 08-05-02 - Loans applied in acquiring an interest
See MoreAustralia: Guidelines on attribution of ADI equity capital and controlled foreign entity equity
On 24 January 2018, the Australian Taxation Office (ATO) issued the Practical Compliance Guideline (PCG) 2018/1. This Guideline sets out how the ATO will administer subsection 820-300(3) of the Income Tax Assessment Act 1997 (ITAA
See MoreIndia: Proposes to introduce thin capitalization rule
Based on India's commitment to counter tax avoidance, recently the Finance Bill, 2017 has proposed to introduce new section i.e. section 94B namely Limitation on interest deduction in certain cases. The said section is in line with the
See MoreMalaysia: Thin capitalization rules deferred till 2018
The Ministry of Finance has issued a noticed on 30 December, 2015, regarding the effective date of the Income Tax (Thin Capitalization) Rules. The Rules has been deferred to till 2018 and will take effect from 1 January
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