Ireland updates transfer pricing documentation obligations
On 3 August 2017, Irish Revenue published a Tax and Duty Manual Part 35a-01-02 dealing with Transfer Pricing Documentation Obligations. The contents of this manual were previously included in Tax Briefing 07 of
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Poland: Financial services-Restriction on interest deduction: According to draft bill revising on corporate income tax act published on 12 July 2017, thin capitalization rules limiting the deduction of financing costs to 30% of an adjusted tax
See MoreIsrael: District Court makes a decision on Israeli transfer pricing rules
A decision was made and governed by an Israeli District Court that when an Israeli company gained IP ownership and shortly thereafter its employees and other assets (with IP) to a related party, the transfer should be counted as a sale for whole
See MoreGermany publishes revised guidance on CbC reporting requirements
The Germany Federal Ministry of Finance (MoF) on 11 July 2017 issued guidance on the Country-by-Country (CbC) reporting requirements in line with BEPS Action 13 and the EU Administrative Assistance Directive as amended. If certain requirements are
See MoreIceland: Parliament passes legislation amending to interest deduction
The parliament has passed legislation amending article 57(b) of the Income Tax Act No. 90/2003 on 1st June 2017. According to the previous article 57 (b) of the Income Tax Law No 90 /, which entered into force on 1 January 2017, the taxpayer’s
See MorePanama aims to introduce advance pricing agreements
Panamanian Tax Authority (DGI) began a consultation to amend Article 762-L of the tax code to introduce advance pricing agreements (APAs) on transfer pricing issues. The DGI has twelve months to issue a decision and the decisions of the DGI are
See MoreIndia: CBDT issues final rules for valuation of unquoted shares
The Central Board of Direct Taxes (CBDT) on 12 July 2017 has issued a notification prescribing the method for valuation of unquoted shares for the purposes of Section 56(2)(x) and Section 50CA of the Income-tax Act 1961. The rules will be effective
See MoreAustralia: CbC reporting local file instructions now available
On 4 July 2017, the Australian Taxation Office (ATO) published CbC reporting local file instructions together with some guidance on the meaning of “at the same time” for the purposes of the administrative solution. It allows reducing disclosures
See MoreGreece: Draft law regarding TP documentation requirements for CbC reporting
The Parliament of Greece introduced a draft Law 4484/2017 on July 20, 2017 that amends to the Corporate Income Tax Law L.4170 / 2013 and 4474/2017. The suggested amendments contain additional transfer pricing documentation requirements corresponding
See MoreCzech Republic: Chamber of Deputies passes legislation to implement CbC reporting
The chamber of deputies approved a legislation that implements a new information exchange duty, i.e. country-by-country (CbC) reporting into Czech legislation. The legislation will be effective when all legislative and processes are done. According
See MoreCyprus: Tax Authority issues guidance on revised transfer pricing framework
On 30 June 2017, the Cyprus Tax Authorities (CTA) published a Circular revising the transfer pricing framework for companies carrying out intra-group financing activities in Cyprus. The Circular defines intra-group financing transactions as all
See MoreItaly: Revised transfer pricing rules
Decree No. 50 published on 24 April 2017 was implemented on 15 June 2017. According to Article 59 of Decree Law No 50/2017, a corresponding downward adjustment leading to a lower taxable income will no longer be subject to a mutual agreement
See MoreJapan issues guidance concerning customs valuation opinion
Japan’s customs bureau has recently issued guidance “customs valuation opinion” concerning how retroactive transfer price adjustments are to be addressed from a customs valuation perspective. The customs agency will consider adjustments as
See MoreGermany releases guidance on CbC reporting requirements
The Germany Federal Ministry of Finance on 11 July 2017 issued guidance on the Country-by-Country (CbC) reporting requirements in line with BEPS Action 13 and the EU Administrative Assistance Directive as amended. The guidance clarifies the
See MoreVietnam: National Assembly passes the new technology transfer law
The National Assembly of Vietnam on 19 June 2017 approved the Law on Technology Transfer No. 07/2017 / QH14 ("LTT 2017"). The new law (LTT 2017) comes into force on 1 July 2018 and replaces the Law on Technology Transfer No. 80/2006 / QH11 of 29
See MoreMalaysia: IRBM updates the guidelines for transfer pricing
The Inland Revenue Board of Malaysia (IRBM) had recently announced new updates and changes to the Transfer Pricing Guidelines 2012 (“TPG 2012”). The Malaysian Transfer Pricing Guidelines explain the provision of Section 140A in the Income Tax
See MoreFinland: Tax administration publishes guidance on the allocation of profits to PEs
On 13 June 2017, the Tax Administration published guidance on the allocation of profits to a permanent establishment (PE). A permanent establishment in Finland is liable to Finnish taxation on profits arising in Finland. Permanent establishment
See MoreUS: IRS releases final versions of CbC form and instructions
The Internal Revenue Service has recently released final versions of the form and instructions for filing country-by-country (CbC) reports. Parent entities of U.S. multinational enterprise (MNE) groups with $850 million or more of revenue in a
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