Greece: New Transfer Pricing Documentation Rules
The Greek Parliament passed Income Tax amendments in January 2013 which changes to the transfer pricing provisions have been included. In Greece’s income tax law Article 39 and 39A have been repealed by new measures. According to the amendments
See MorePhilippines: Transfer Pricing Regulations
On 23 January 2013, the Philippines Secretary of Finance issued transfer pricing regulations (Revenue Regulation (RR) No. 02-2013). The regulations provide guidance for applying the arm’s length principle for pricing in related-party transactions
See MoreEcuador: New transfer pricing reporting requirements
The Internal Revenue Service of Ecuador published Resolution NAC-DGERCGC13-00011 on 24 January 2013. Resolution NAC-DGERCGC13-00011 modifies Resolution NAC-DGER2008-0464 on transfer pricing reporting requirements. According to Resolution
See MoreNigeria introduced new TP regulations
Nigeria has announced new Transfer Pricing Regulations on October 22, 2012. This will be applicable retroactively to August 2, 2012. The TP Regulations provide that all transactions between connected parties should be at arm’s length. Taxpayers
See MoreCanada: CRA issues transfer pricing memoranda
The Canada Revenue Agency (CRA) has to follow the OECD Guidelines when performing transfer pricing audits. Two new transfer pricing memoranda (TPM-13 & TPM-14) have been issued. TPM-13 deals with referrals to the Transfer Pricing Review
See MoreNorway: the amount of transfer pricing adjustments doubles
On June 22, 2012 the Norwegian tax authorities (Skatteetaten) announced total transfer pricing adjustments for 2012 of NOK 16.6 billion (approximately U.S. $ 2.8 billion / € 2.2 billion), whereas, in 2010, the total amount was NOK 8.5 billion. In
See MoreAustralia: New Transfer Pricing Rules
On 22 November 2012, an exposure draft was released introducing new Australian transfer pricing rules with significant self assessment and documentation requirements. Interested parties were invited to comment on the exposure draft. The start date
See MoreIrish Revenue announces transfer pricing compliance monitoring approach
On 6 December 2012 it was published that the Irish Revenue released guidance on 26 November 2012 setting out how they are proposing to monitor transfer pricing compliance in accordance with Part 35A of the Taxes Consolidation Act 1997 The guidance
See MoreColombia: Transfer pricing documentation and APA requirements amended
It was reported on 29 August 2012 that, decree 1602, published in the Official Gazette of 27 July 2012, modifies some of the transfer pricing regulations established by Decree 4349 of 2004. Some of the most important modifications, applicable as
See MoreTransfer Pricing Brief: August 2012
Belgium There are no specific provisions in relation to financial services, but fees must conform to the arm's length principle. Thin capitalization rules apply to restrict the tax deduction for interest on loans between related companies or loans
See MoreIndia- introduction of an APA program
The Finance Minister of India introduced the Finance Bill, 2012, on 16 March 2012 in which with respect to transfer pricing, the introduction of an advance pricing agreement (APA) program as well as other transfer pricing-related items has been
See MoreRussia- Introduces new Transfer Pricing Rules
New Federal Law FZ-227 of 18 July 2011 which enacted comprehensive transfer pricing rules entered into force on 1 January 2012. According to the new Law, companies falling under the scope of transfer pricing rules will be obligated to disclose
See MoreLithuania- APA
The amendment to the Tax Administration Law applicable from 1 January 2012, enables taxpayers to apply for advance transfer pricing agreements with the tax administrator. Agreements between taxpayers and the tax administrator on transfer pricing
See MoreUK: Latest Transfer Pricing Statistics Released
HM Revenue and Customs (HMRC) settled the UK’s Transfer Pricing rules such a way that the pricing of transactions between connected can result into an increased revenue yield. The internationally recognized ‘arm’s length principle’ is
See MoreNew transfer pricing form issued by Malaysia’s tax authority
Malaysia’s Inland Revenue Board (IRB) has issued a new form to collect information on transfer pricing compliance, and enforce transfer pricing rules for the corporate taxpayers. The IRB targeted the corporate taxpayers because they have
See MoreTransfer pricing gets intensive focus in Vietnam’s General Department of Taxation
During the late July 2011 Vietnam’s General Department of Taxation (GDT) and HCM tax authorities took several activities on transfer pricing (TP) which focused importantly on increasing awareness and strengthening the implementation of TP
See MoreAuthorities’ use of net-back approach in transfer pricing case has been overruled by the Russian Court
The Federal Arbitration Court of the Moscow Region rejected the Russian Tax Authorities’ attempt to adjust a taxpayer’s transfer pricing by applying the net-back approach. The net-back method are applied to oil production and operates by taking
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