India: Transfer Pricing Adjustment For Interest-Free Loan to Related Party
Recently, the Income-tax Appellate Tribunal upheld an interest adjustment on a loan that the taxpayer advanced to a related entity In the case of: Soma Textile & Industries Ltd. v. ACIT. Here the tribunal found that the comparable uncontrolled
See MoreSri Lanka: Commissioner General of Inland Revenue publishes gazette on Transfer Pricing Regulations
The Commissioner General of Inland Revenue has published gazette no. 1907/26 dated 25 March 2015 on Transfer Pricing Regulations. It was made available on the Government Printer’s website on 27 May 2015. The gazette requires the taxpayer to
See MoreSpain: BEPS country by country reporting provisions enacted
The Spanish Ministry of Finance published Royal Decree 634/2015 of 10 July 2015 in the Official Gazette on 11 July, 2015. The Decree contains corporate income tax regulations including (BEPS) country by country reporting requirements in line
See MoreGreece: tax authorities issue circular to clarify transfer pricing regulations
The Greek tax authorities issued circular no. POL 1142/02.07.2015 dated July 2, 2015 to explain transfer pricing (TP) documentation issues raised in light of the new Income Tax Law no. L. 4172/2013 and Tax Procedures Code no. L. 4174/2013. The
See MoreNew guidance on Advance Pricing Agreements issued by Australian Taxation Office
The Australian Taxation Office released its revised policies and procedures for the Advance Pricing Agreements program on 23 July 2015. The updated guidance has been provided in the form of Practice Statement Law Administration PSLA 2015/4, which
See MoreGermany plans to adopt BEPS guidance on transfer pricing documentation and CbC reporting requirement
The German government has announced plans to incorporate guidance on transfer pricing documentation and country-by-country (CbC) reporting) in line with the OECD’s Base Erosion and Profit Shifting (BEPS) project into local legislation. The
See MoreSlovenia: Â Procedures for Advance Pricing Agreements
The Ministry of Finance has published proposed changes to the Slovenian Tax Procedure Act. The envisaged amendments bring a broad variety of important amendments regarding automatic exchange of information and elimination of administrative
See MoreUruguay: New rules for depreciating intangible assets
The government of Uruguay has modified the rules for depreciating intangible assets through Decree No. 181/015 of 6 July 2015. The new rules have changed the general depreciating period for intangible assets acquired from 1 July 2015. Taxpayers
See MoreIndia: High Court affirms that comparables must be functionally similar
In the case of: CIT-I v. DSM Anti Infectives India Ltd. ITA No. 116 of 2014 the Punjab and Haryana High Court confirmed a judgment of a tax appellate tribunal that certain companies selected in a search for comparables in a transfer pricing analysis
See MorePoland: Published revised draft bill on transfer pricing documentation
Poland’s Government published the revised draft of the Personal Income Tax /Corporate Income Tax Act (Bill) concerning documentation of intercompany transactions on 18 June 2015. According to the revised draft, the management or control
See MoreTransfer Pricing Brief: June 2015
India: Intangible property: The Delhi High Court ruling on marketing intangibles in the Sony Ericsson Mobile Communications India Pvt. Ltd. case provides clear guidance on how the issue of marketing intangibles should be viewed in cases where
See MoreIndia: Delhi High Court Expresses Its View on Marketing Intangibles
Recently, the Delhi High Court issued its much anticipated ruling on marketing intangibles in the Sony Ericsson Mobile Communications India Pvt. Ltd. case. The High Court ruling is partially in favor of the taxpayers engaged in the import,
See MoreBangladesh: Changes in Transfer Pricing Provisions in Finance Bill 2015 Passed by Parliament
The Bangladesh Parliament passed the Finance Bill 2015 on June 29, 2015 with some changes in the transfer pricing provisions. The legislation relating to the report from an accountant required to be furnished by a person who has entered into
See MoreSlovak Republic: New transfer pricing documentation guidance
The Finance Ministry has issued new guidance on transfer pricing documentation. This guidance creates three categories of documentation based on the degree of detail of the information required in relation to a taxpayer’s risk profile. The
See MoreTransfer Pricing Brief: May 2015
India: Comparable Data Range: The company having high or extremely high profits and losses should not be the only consideration to exclude as a comparable company for purposes of determining the arm’s length price but other matters like
See MoreThailand: Draft Act contains new transfer pricing provisions
The Cabinet of Thailand approved a draft Act on Revenue Code Amendment on 7 May 2015. If enacted the Act would introduce specific transfer pricing provisions into the Revenue Code and also would amend the tax law of Thailand to apply transfer
See MorePoland: Draft Regulation Introducing Amendments Based on BEPS Documentation Requirements
The Polish Ministry of Finance published a draft regulation on 27 April 2015 which introduced amendments on transfer pricing documentation in line with the requirements of the OECD/G20 action plan on base erosion and profit shifting
See MoreItaly: Draft legislative decree introduces advance pricing agreement rollback provision
A draft legislative decree was approved by the Italian Government on 21 April 2015Â introducing an advance pricing agreement (APA) rollback provision and provisions relating to costs of transactions with tax havens. The draft decree introduces
See More