India: CBDT has withdrawn the guideline of profit-split method for transfer-pricing transactions, and amends the circular on contract R&D

July 08, 2013

The Central Board of Direct Taxes (CBDT) withdrew Circular No. 2/2013 on June 2013as it gives the impression that the profit split method is the preferred method in cases involving unique intangibles or in multiple interrelated international

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Documentation Considered in Malaysia’s First Transfer Pricing Case

July 03, 2013

The Special Commissioners of Income Tax in Malaysia delivered a landmark decision on February 2013 in the favour of the taxpayer in the first transfer pricing litigation in Malaysia. The case concerned assessments on a shipping and logistics

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Indonesia: New Regulation on Transfer Pricing Audits

July 03, 2013

Regulation PER 22/PJ/2013 has been published by the Indonesia’s Directorate General of Taxation (DGT) on 30 May 2013 to provide guidelines for audits of taxpayers with related-party relationships and repealed the regulation KEP-01/PJ 07/1993

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India: CUP method for benchmarking service contracts

July 03, 2013

In a recent decision of Income Tax Appellate Tribunal (“ITAT”) it was held that for benchmarking service contracts when comparable data for these contracts is available the comparable uncontrolled price (CUP) method is the most suitable method.

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Hungary: New Decree on Transfer Pricing Documentation Rules

July 03, 2013

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

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France: report on tax evasion, transfer pricing

July 03, 2013

The French Minister of Economy and Finance published an official report on transfer pricing legislation on 5 June 2013. The report concludes that France’s transfer pricing rules are out of step with international counterparts. The French General

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Czech Republic: New Decree on Low Value Adding Services

July 03, 2013

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

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Poland: Amendment on the Advance Pricing Agreements

June 18, 2013

Poland’s Ministry of Finance proposed changes on 11 June 2013 that might amend the provisions concerning advance pricing agreements (APAs) if sanctioned. Changes in the APA - Extended the scope of transactions to APAs by repealing current law

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India: Transfer Pricing Reporting Requirements

June 18, 2013

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

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India: Extensive Guidance Note on APA

June 18, 2013

Recently the Central Board of Direct Taxes (CBDT) of India published a comprehensive APA Guidance Booklet concerning India’s advance pricing agreement (APA) program, detailing the procedural aspects of unilateral, bilateral or multilateral APA

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India: Listed price cannot be used under the Comparable Uncontrolled Price (CUP) method

June 18, 2013

In a recent decision, the Chennai Bench of the Income-tax Appellate Tribunal held that the list price on a manufacture’s website is only an “indicative price” and so the list price alone cannot be used to determine the arm’s length price of

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France: IGF recommends strengthening control of transfer pricing

June 18, 2013

The French tax authorities released a report on 11 June 2013 regarding recommendations aimed at strengthening existing transfer pricing rules applicable to international groups in France, to better combat tax optimization and avoidance by

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OECD: Revised Section E on Safe Harbours

June 11, 2013

The Organisation for Economic Co-operation and Development (OECD) Council approved the Revised Section E on safe Harbours in Chapter IV of the Transfer Pricing Guidelines, on 16th May 2013. The Revised Section E (Section E) contains only nine pages,

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Australia: Practice statement on Transfer Pricing

June 11, 2013

The Australian Customs and Border Protection Service (Customs) has published Practice Statement B_IND08 “Valuation-Transfer Pricing Policy” and this new practice statement will replace Practice Statement PS 2009/21 on the subject. The

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Argentina: New process for determining “tax haven” jurisdictions

June 11, 2013

Argentina’s tax authority (AFIP) has issued a decree introducing new criteria for when to consider countries as “tax haven” jurisdictions for transfer pricing purposes. This Decree was published on May 30, 2013. The Decree states that the AFIP

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Hungary: Draft bill on the proposed changes to transfer pricing reporting obligations

June 04, 2013

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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Russia: Offering New Transfer Pricing Deadlines

May 16, 2013

The Russian government has sent Draft Law No. 79859-6, which offers to set new transfer pricing deadlines for taxpayers for the second reading to the lower house of the Russian parliament. These changes may impact international businesses operating

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Brazil: Expands Threshold for Companies for presumed Profit Method

May 16, 2013

The profit method is one of four calculation regimes that may be applied by some companies for the computation of profits for Brazil’s corporate income tax. This is a simplified regime that enables a company to pay tax based on a percentage of its

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