South Africa: SARS published Transfer Pricing documentation proposal for public comments
The South African tax authorities published for public comments a Draft Notice on additional Transfer Pricing record-keeping requirements. Where a person has entered into a potentially affected transaction, the aggregate of the transaction for the
See MoreUkraine: Tax authorities defines the controlled transaction
Recently the Ukrainian tax authorities issued a Guidance Letter No. 14491/6/99-99-15-02-02-15 regarding transactions with related non-residents of Ukraine, and transactions with residents of low-tax jurisdictions and sales of goods through a
See MoreUK: Consultation on tax simplification for unincorporated businesses
On 15 August 2016 HMRC published a consultation document on simplifying tax for unincorporated business. The UK government announced at Budget 2016 that it would be looking at simplifying tax rules for businesses, with a focus on the self employed
See MoreLuxembourg: Government submitted draft law on CbC reporting to the Luxembourg Parliament
Recently the Luxembourg Government submitted draft law n°7031 on country by country (CbC) reporting to the Luxembourg Parliament. The draft law is in accordance with a European Union (EU) Directive of 25 May 2016 requiring all EU Member States
See MoreUruguay-Bill on adoption of CbC reporting, Master file documentation and the availability of bilateral and multilateral APAs
The Uruguay Government has submitted to Congress a tax bill including adoption of the OECD’s recommendations for Country-by-Country (CbC) reporting following the scope of information to be provided under the Base Erosion and Profit Shifting (BEPS)
See MoreCzech Republic: Announcement regarding country by country reporting
The Finance Ministry of Czech has made an announcement on 11th August 2016 that it started a public consultation on a bill which would introduce changes to the Law on International Cooperation in Tax Administration. In particular, the bill would
See MoreIndia: The tribunal held the Comparable Uncontrolled Price is the most appropriate method
The Delhi Bench of the Income-tax Appellate Tribunal upheld the decision in the case of: Liugong India Private Ltd. v. ACIT (ITA No. 1482/Del/2015) and decided that when comparable are available, the CUP method is the best method to use in
See MoreCanada: Country-by-country reporting legislation introduced
Following on the Organization for Economic Cooperation and Development’s (OECD) Base Erosion and Profit Sharing (BEPS) initiative, the Finance Department has released draft legislative proposals on 29th July 2016 that would implement certain
See MoreTransfer Pricing Brief: July 2016
Austria: BEPS Related Compliance Master file information: Austria has introduced a requirement for a master file for constituent entities resident in Austria if their turnover in the previous two fiscal years exceeded €50 million in each year.
See MoreIreland published new APA guidelines
The Irish Revenue published bilateral advance pricing agreement guidelines on June 23 relating to the operation of Ireland’s APA program, which is effective for applications received on or after July 1, 2016. The guidance outlines the framework of
See MoreMexico: Government passes new transfer pricing rules for APA
The Mexican government recently passed a new regulation to permitting the Mexican Tax Authorities to perform on-site visits to carry out their own functional analysis as a part of the Advanced Pricing Agreement (APA) process. Rule 2.12.8 published
See MoreSlovak Republic: MoF publishes a guideline regarding TP documentation
The principle of transfer pricing is the pricing of goods, services and so on in related party transactions surrounded by multinational enterprises to fulfill the conditions for a self-governing business relationship or to meet the arm’s length
See MoreGreece: Bill regarding transfer pricing provisions enacted
The Greek Parliament has approved a bill of the Finance Ministry on 27th July 2016 introducing significant changes regarding the transfer pricing documentation provisions. The bill, inter alia, amended various provisions of the Greek Tax Procedure
See MoreChina issued new rules on TP documentation requirement
China issued Bulletin 42 to introduce a requirement for a master file for MNC group resident in China if their annual inter-company transaction amount exceeds RMB 1 billion. The master file requirement is effective from fiscal year 2016. A master
See MoreBelgium issued new rules on CbC reporting and TP documentation requirement
Belgium issued regulation to introduce a requirement for a master file and a local file for MNC group resident in Belgium if it satisfies one of the three thresholds like a sum of operational and financial income of €50 million; or a balance
See MoreKorea: Revised draft legislation on transfer pricing and country-by-country reporting
The South Korean Ministry of Strategy and Finance has recently released a draft legislation which would amend the existing provisions of Article 11 of the Korean Law which is known as the “Law for the Coordination of International Tax Affairs”
See MoreAustria: Publishes government bill of new Transfer Pricing Documentation Law
Finance (MoF) published the government bill of the European Union (EU) Tax Amendment Act 2016, including among other provisions, the new Austrian Transfer Pricing Documentation Law (TPDL). This follows the publication of the draft TPDL on 9 May 2016
See MoreIndia: Tribunal held that Transfer Pricing Officers have the authority to determine the arm’s length price
The Delhi Bench of the Income-tax Appellate Tribunal in the case of: Nikon India Pvt. Ltd. v. DCIT (ITA No. 6314/Del/2015), held that Transfer Pricing Officers have the authority to determine the arm’s length price of any international transaction
See More