India: 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 MoreJapan: Publishes guidance under new transfer pricing documentation rules
Japan's national tax agency has released guidance concerning new transfer pricing documentation rules. The guidance released on 30 June 2016 and under Japan's 2016 tax reform, amendments were made to the Japanese transfer pricing documentation
See MoreGreece: A draft bill submitted to parliament
A draft bill was submitted to the parliament on 13th July 2016 for amending unified property tax, Procedural Tax Code and transfer pricing legislation. In accordance with the draft bill, the General Secretary of Public Revenue may discharge very
See MoreOECD: Revised guidance on profit splits
On 4 July 2016 the OECD released a consultation document containing revised guidance on profit splits. This is part of the follow-up work on BEPS actions 8 to 10 in relation to assuring that transfer pricing outcomes are in line with value creation.
See MorePlatform for Collaboration on Tax releases discussion draft on effective capacity building
The Platform for Collaboration on Tax was set up by the IMF, OECD, UN and World Bank at the request of the G20 group of countries to recommend mechanisms to ensure effective implementation of technical assistance programs. The February 2016 meeting
See MoreColombia: DIAN issued Administrative Regulation for filing the transfer pricing informative return
The Colombian National Tax Authority (DIAN) issued an Administrative Regulation 50 of 16 June 2016 regarding the procedure and technical conditions for filing the transfer pricing informative return for the tax year 2015. In this Administrative
See MoreTransfer Pricing Brief: June 2016
UK: Secondary adjustment: HMRC launched a consultation on May 26, 2016 to introduce and design secondary adjustment rule into the transfer pricing legislation of UK. See the story in Regfollower Germany: BEPS related compliance General rule for
See MoreBelgian Government approved new draft legislation to implement TP documentation and CbC reporting requirements
The Government of Belgium has approved new draft legislation to effectively implement CbC reporting and introduce formal transfer pricing documentation requirements in Belgium. The draft legislation is according to 3 tiered approach of Action 13 of
See MoreJapan: The penalty for failure to submit the CbC report or the Master File by the due date
Japan’s 2016 tax reform was enacted on 29 March 2016 and at the end of April 2016, the National Tax Agency posted guidance on its website to help clarify the documentation requirements within Japan. The tax reform also implements penalties for a
See MoreSingapore: Commits to implement CbCR for financial years beginning on or after 1 January 2017
The Ministry of Finance announced on 16 June 2016, that Singapore will join the inclusive framework for the global implementation of the Base erosion and profit shifting (BEPS) Project. Under this framework, all state-and non-state jurisdictions
See MoreTanzania issues Finance Bill, 2016
Tanzania’s Finance Bill 2016 was made publicly available on 13th June 2016. This follows presentation of the 2016/17 budget by the Finance Ministry on 8th June 2016. This covers the Finance Bill, 2016 which contains numerous proposed changes in
See MoreCosta Rica: Tax authority released draft rules for annual transfer pricing return
The Costa Rican tax authority released a draft rules on 6 June 2016 for taxpayers to apply and follow in filing an annual transfer pricing return. The draft resolution includes a penalty for taxpayers that fail to file a transfer pricing return,
See MoreAustralia: Electronic Local Files template finalized
Taxpayers that fail to adhere to their tax disclosure obligations like submitting local file will be exposed to administrative penalties of AUD 4,500. The Government proposes revised penalties amounting to AUD450, 000 from 1 July 2017 for failure to
See MorePoland: President signs GAAR provisions
The President of Poland has signed the bill amendments to the Tax Code including the General Anti-Abuse Rule (GAAR) requirements on 7 June 2016 and it is likely that GAAR will be introduced in July 2016. GAAR provisions will provide some tax
See MoreGreece: Transfer pricing obligations of acquiring company in case of merger
The Public Revenue Authority has published a legal document entitled "ΔΕΑΦΒ 1086197 ΕΞ 2016" on 2nd June 2016 for providing clarifications that the acquiring company is responsible for the submission of the relevant transfer pricing
See MoreAustria: Proposes legislation on Transfer Pricing documentation and CbC reporting
The Austrian Ministry of Finance (MoF) has published draft legislation to implement the Master File in line with the new OECD standard. The legislation includes a requirement to prepare a Master file, Local file(s), and CbCR. The new requirements
See MoreTransfer Pricing Brief: May 2016
Sweden: BEPS related compliance Master File information: The Swedish Tax Agency has submitted a proposal to the Swedish Government for new Transfer Pricing documentation like Master File. Under the current proposal, the Master File reporting
See MoreGermany: Ministry of Finance introducing CbCR, Master File and Local File
The German Ministry of Finance published a draft bill on 1 June 2016 to incorporate guidance on transfer pricing documentation and country-by-country (CbC) reporting into local legislation. The draft bill required multinationals with consolidated
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