Italy-Ministerial Decree implementing Country-by-Country Reporting issued
The Italian Ministry of Finance issued a Decree on 8 March 2017 providing detailed information regarding the application of CbC reporting rules. The Decree is in accordance with an EU Directive of 25 May 2016 requiring all EU Member States to
See MoreVietnam: Recently released a new transfer pricing decree
Vietnam’s Government has recently released a Transfer Pricing (“TP”) Decree No. 20/2017/ND-CP on 24 February 2017, provided that tax administration applicable to enterprises having controlled transactions’ (Decree 20), which will take effect
See MoreIndia: Delhi High Court removed the penalty assessment for related-party transactions
The Delhi High Court, in the case of: Pr.CIT v. Mitsui Prime Advanced Composites India Pvt. Ltd. (ITA 913/2016, CM APPL.46519/2016), dismissing tax department’s appeal and upheld the Tribunal’s order deleting penalty under Section 271(1)(c) of
See MoreChina concludes first cost sharing agreement APA
The State Administration of Taxation (SAT) of China recently concluded the first advance pricing agreement (APA) for a cost sharing agreement (CSA) with a Fortune 500 enterprise in Guangdong Province. The CSA-APA focuses on international R&D
See MoreSweden publishes regulation on automatic exchange of CbC reporting
The regulation on the automatic exchange of country-by-country (CbC) reporting (the Regulation) was published in the Official Gazette on 14 March 2017. The law proposal had been adopted on 1st March 2017. The Regulation, which will enter into force
See MoreOECD: Extended deadline for comments on draft toolkit on comparables
The deadline has been extended for comments to be submitted on the draft toolkit issued by the Platform for Collaboration on Tax dealing with the ways developing countries can overcome the problem of a lack of comparable data for transfer pricing
See MoreRussia: Publishes the draft procedure on multilateral APAs
The Russian Finance Ministry on 3 March 2017, published a draft Procedure outlining the process for handling multilateral Advanced Pricing Agreements (APAs). The Procedure is intended to enable a taxpayer to conclude an APA in relation to a foreign
See MoreCzech Republic: Tax audits focused on transfer pricing increases
The number of tax audits focused on transfer pricing in the Czech Republic and the resulting tax adjustments have increased rapidly because of Czech Tax Administration’s systematic risk assessments. These risk assessments are successively used to
See MoreIndia: Related-party Relationship Upheld by The Tribunal
Recently, the Chennai Bench of the Income-tax Appellate Tribunal (the Tribunal) in the case of: Hospira Healthcare India Private Limited v. DCIT (ITA No. 821/Mds/2016 - AY 2011-12), held that under a provision of India’s tax law, “influence”
See MoreCanada: Guidance about CbC reporting
The Canada Revenue Agency (CRA) has released a Guide ‘RC4651’ on 2nd March 2017 regarding Country-By-Country Reporting (CbCR) in Canada, which is only available in electronic format. This is a new filing obligation for multinational enterprise
See MoreFinland: Ministry of Finance declares their commitment to exchange CbC reports
Finland is committed to the exchange of the country-by-country (CbC) report. On March 8, 2017, an official Gazette was published by the Ministry of Finance. The Gazette states that the government is willing to comply with the Multilateral Competent
See MoreIndia signs fifth bilateral advance pricing agreement with Japan
On 6 March 2017, India has signed a bilateral advance pricing agreement with the Indian subsidiary of a Japanese company, India's Central Board of Direct Taxes (CBDT) has announced. With this agreement, India and Japan have concluded five bilateral
See MoreSweden approves the new legislation on transfer pricing documentation and CbC reporting
Sweden's parliament on 1 March 2017, adopted the government’s proposal on transfer pricing documentation and country-by-country reporting. The adoption amounts to the ratification of OECD’s guidelines for transfer pricing documentation and
See MoreAustralia releases guidance on IRP agreements
The Australian Taxation Office (ATO) released guidance on providing international related-party agreements (IRPA) as part of Part B of the local file for country-by-country reporting (CbCR), on 3 March 2017. The taxpayer is required to provide
See MoreTransfer Pricing Brief: February 2017
Ukraine: Controlled transaction: As per the amended Tax Code effective from 1 January 2017, a transaction is considered controlled if the annual income of the taxpayer within the reporting period exceeds UAH 150 million, and the sum of the
See MoreAustralia: ATO releases PCG on simplified transfer pricing record-keeping
On 22 February 2017 the Australian Taxation Office (ATO) released Practical Compliance Guideline (PCG) 2017/2 dealing with simplified transfer pricing (TP) record-keeping options and assisting taxpayers in complying with relevant tax laws. The PCG
See MoreCyprus: Cyprus: Tax Authority abolishes minimum margins on loans effective from 1 July 2017
The Cypriot Tax Authorities (CTA) has announced their intention of withdrawing the Minimum Margin scheme (the MMS) with effect 1 July 2017. It is being reminded that in accordance with Article 33 of the Cyprus Income Tax Law, all transactions
See MoreUkraine: Amendments to tax code effective from 1 January 2017
The amendments to the Tax Code have been effective, with some exceptions, since 1 January 2017. Below is a summary of the most significant changes in corporate profit tax and transfer pricing. Corporate profit tax: The general tax rate remains
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