US: IRS publishes draft instructions for Form 8975, Country-by-Country Report
The Inland Revenue Service has published, on 23 February 2017, draft version of instructions for forms that multinational enterprise (MNE) groups are to use in filing information on a country-by-country basis. Form 8975 and Schedules A (Form 8975)
See MoreIndia: Tribunal holds that resale price method is most appropriate method
The Delhi Bench of the Income-tax Appellate Tribunal in the case of: Swarovski India Private Ltd. v. ACIT (ITA No. 5621/Del/2014 and ITA No. 5622/Del/2014), held that the resale price method is the most appropriate method to benchmark an
See MoreJapan introduces CbC reporting notification requirements
Recently, Japan has introduced notification requirements related to Country-by-Country Reporting (CbCR) in line with the Organization for Economic Co-operation and Development (OECD) action plan on Base Erosion and Profit Shifting (BEPS)
See MoreSouth Africa: Transfer pricing proposals in 2017 budget
The Finance Minister of South Africa on 22 February 2017 delivered the budget speech to Parliament. In his speech the Minister mentioned the government’s plan for implementing a statutory transfer pricing regime in South Africa. The government
See MoreGreece: Deadline for TP file submission for two investment projects extends
A press release has been published by the Finance Ministry on 16th February 2017. It states that the deadline for the transfer pricing (TP) file submission concerning the investment projects General Entrepreneurship (Γενική
See MoreColombia: Tax reform 2016 and Transfer Pricing Updates
In accordance with law 1819 of 2016, adopting the structural tax reform bill approved on 23 December 2016, introduces the following main changes to the transfer pricing regime. According to article 260-3 of the Tax Code (TC), as amended by the tax
See MoreIsrael: Transfer pricing amendments has been proposed
The Parliament approved the bill regarding country-by-country (CbC) reporting on 1st February 2017. It must be published in the collection of laws for becoming law. This bill will become effective as from 1st March 2017. It was submitted to the
See MoreSlovak Republic: Bill on CbC reporting approved
The Parliament approved the bill regarding country-by-country (CbC) reporting on 1st February 2017. It must be published in the Collection of Laws for becoming law. This bill will become effective as from 1st March 2017. It was submitted to the
See MoreAustralia: DPT Bill includes updated transfer pricing guidelines
On 9 February 2017, the Australian Government introduced legislation into the Parliament to implement the new Diverted Profits Tax (DPT), which will prevent multinationals shifting profits made in Australia offshore to avoid paying tax. The Diverted
See MoreCanada: CbC report form published
A form entitled ‘RC 4649’ and instructions for completing the country-by-country (CbC) report has been published on 3rd February 2017 by the Canada Revenue Agency (CRA) for reporting the income allocation, tax allocation and business activities
See MoreIndia: Proposes to introduce thin capitalization rule
Based on India's commitment to counter tax avoidance, recently the Finance Bill, 2017 has proposed to introduce new section i.e. section 94B namely Limitation on interest deduction in certain cases. The said section is in line with the
See MoreSwitzerland clarifies procedure for recovery of interest paid
The Federal Finance Department has explained the refund procedure regarding the recovery of interest paid for late reporting of intra-group dividend distributions on 1 February 2017. The explanation results from revisions of the procedure for
See MoreIndia: Proposes amendments to the transfer pricing regulations
Indian Finance Minister published India’s 2017-18 budget on 1 February 2017. Along with other measures, the budget has proposed following important amendments to the provisions of transfer pricing (TP) regulations of India: –A major proposal in
See MoreTransfer Pricing Brief: January 2017
Azerbaijan: Transfer pricing rules: Law No. 454-VQD of 16 December 2016 establishes new transfer pricing (TP) rules for certain transactions. The new TP rules cover transactions whose total value exceeds AZN 500,000 (approximately USD 278,000) in
See MoreSingapore: IRS publishes Transfer pricing guidelines 2017
The Inland Revenue Authority of Singapore published the 4th version of transfer pricing guidelines on 12 January 2017, demonstrating compliance with international transfer pricing standards. The published guidelines explicitly refer to the Base
See More7 more countries sign tax co-operation agreement to enable BEPS Action 13
According to a press release of 27 January 2017, published by the OECD, as part of continuing efforts to boost transparency by multinational enterprises (MNEs), Gabon, Hungary, Indonesia, Lithuania, Malta, Mauritius and the Russian Federation have
See MoreNigeria: FIRS issues new TP declaration and disclosure forms
The Federal Inland Revenue Service (FIRS) of Nigeria published new transfer pricing (TP) forms (TP Declaration Form and TP Disclosure Form). This is aimed at improving disclosure and transparency by taxpayers in their TP Returns, and providing FIRS
See MoreEcuador introduces new TP regulations to exports
The Internal Revenue Service of Ecuador has issued a Resolution that was published in the official gazette on 30 December 2016. The Resolution launches transfer pricing (TP) regulations applicable to exports of bananas, oil, petrol, gold, silver,
See More