Russia: Publishes the draft procedure on multilateral APAs
The Russian Finance Ministry on 3 March 2017, published a draft Procedure outlining the process for handling multilateral Advanced Pricing Agreements (APAs). The Procedure is intended to enable a taxpayer to conclude an APA in relation to a foreign
See MoreCzech Republic: Tax audits focused on transfer pricing increases
The number of tax audits focused on transfer pricing in the Czech Republic and the resulting tax adjustments have increased rapidly because of Czech Tax Administration’s systematic risk assessments. These risk assessments are successively used to
See MoreIndia: Related-party Relationship Upheld by The Tribunal
Recently, the Chennai Bench of the Income-tax Appellate Tribunal (the Tribunal) in the case of: Hospira Healthcare India Private Limited v. DCIT (ITA No. 821/Mds/2016 - AY 2011-12), held that under a provision of India’s tax law, “influence”
See MoreCanada: Guidance about CbC reporting
The Canada Revenue Agency (CRA) has released a Guide ‘RC4651’ on 2nd March 2017 regarding Country-By-Country Reporting (CbCR) in Canada, which is only available in electronic format. This is a new filing obligation for multinational enterprise
See MoreFinland: Ministry of Finance declares their commitment to exchange CbC reports
Finland is committed to the exchange of the country-by-country (CbC) report. On March 8, 2017, an official Gazette was published by the Ministry of Finance. The Gazette states that the government is willing to comply with the Multilateral Competent
See MoreIndia signs fifth bilateral advance pricing agreement with Japan
On 6 March 2017, India has signed a bilateral advance pricing agreement with the Indian subsidiary of a Japanese company, India's Central Board of Direct Taxes (CBDT) has announced. With this agreement, India and Japan have concluded five bilateral
See MoreSweden approves the new legislation on transfer pricing documentation and CbC reporting
Sweden's parliament on 1 March 2017, adopted the government’s proposal on transfer pricing documentation and country-by-country reporting. The adoption amounts to the ratification of OECD’s guidelines for transfer pricing documentation and
See MoreAustralia releases guidance on IRP agreements
The Australian Taxation Office (ATO) released guidance on providing international related-party agreements (IRPA) as part of Part B of the local file for country-by-country reporting (CbCR), on 3 March 2017. The taxpayer is required to provide
See MoreTransfer Pricing Brief: February 2017
Ukraine: Controlled transaction: As per the amended Tax Code effective from 1 January 2017, a transaction is considered controlled if the annual income of the taxpayer within the reporting period exceeds UAH 150 million, and the sum of the
See MoreAustralia: ATO releases PCG on simplified transfer pricing record-keeping
On 22 February 2017 the Australian Taxation Office (ATO) released Practical Compliance Guideline (PCG) 2017/2 dealing with simplified transfer pricing (TP) record-keeping options and assisting taxpayers in complying with relevant tax laws. The PCG
See MoreCyprus: Cyprus: Tax Authority abolishes minimum margins on loans effective from 1 July 2017
The Cypriot Tax Authorities (CTA) has announced their intention of withdrawing the Minimum Margin scheme (the MMS) with effect 1 July 2017. It is being reminded that in accordance with Article 33 of the Cyprus Income Tax Law, all transactions
See MoreUkraine: Amendments to tax code effective from 1 January 2017
The amendments to the Tax Code have been effective, with some exceptions, since 1 January 2017. Below is a summary of the most significant changes in corporate profit tax and transfer pricing. Corporate profit tax: The general tax rate remains
See MoreUS: IRS publishes draft instructions for Form 8975, Country-by-Country Report
The Inland Revenue Service has published, on 23 February 2017, draft version of instructions for forms that multinational enterprise (MNE) groups are to use in filing information on a country-by-country basis. Form 8975 and Schedules A (Form 8975)
See MoreIndia: Tribunal holds that resale price method is most appropriate method
The Delhi Bench of the Income-tax Appellate Tribunal in the case of: Swarovski India Private Ltd. v. ACIT (ITA No. 5621/Del/2014 and ITA No. 5622/Del/2014), held that the resale price method is the most appropriate method to benchmark an
See MoreJapan introduces CbC reporting notification requirements
Recently, Japan has introduced notification requirements related to Country-by-Country Reporting (CbCR) in line with the Organization for Economic Co-operation and Development (OECD) action plan on Base Erosion and Profit Shifting (BEPS)
See MoreSouth Africa: Transfer pricing proposals in 2017 budget
The Finance Minister of South Africa on 22 February 2017 delivered the budget speech to Parliament. In his speech the Minister mentioned the government’s plan for implementing a statutory transfer pricing regime in South Africa. The government
See MoreGreece: Deadline for TP file submission for two investment projects extends
A press release has been published by the Finance Ministry on 16th February 2017. It states that the deadline for the transfer pricing (TP) file submission concerning the investment projects General Entrepreneurship (Γενική
See MoreColombia: Tax reform 2016 and Transfer Pricing Updates
In accordance with law 1819 of 2016, adopting the structural tax reform bill approved on 23 December 2016, introduces the following main changes to the transfer pricing regime. According to article 260-3 of the Tax Code (TC), as amended by the tax
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