Taiwan – Separate analysis for certain controlled transactions
Taiwan’s Ministry of Finance issued guidance that relaxes the rules requiring a separate analysis for controlled transactions. Under the transfer pricing safe harbor rules (from 2008), a profit-seeking enterprise is required to prepare a transfer
See MoreFinland: Government Issues Proposal To Change Transfer Pricing Rules
The Finnish government issued a draft proposal on 7 January 2015 that would amend the transfer pricing rule in section 31 of the Tax Procedure Act. Comments are due by 20 February 2015. Information on the effective date for the amendment is not
See MoreAzerbaijan: The Ministry of Taxes and the IFC are Working to Protect Withdrawal of Profits from Taxation
The Ministry of Taxes of Azerbaijan and the International Finance Corporation (IFC) are working on a draft agreement on transfer pricing. The aim is to protect withdrawal of profits from Taxation. Azerbaijan will be able to go to the international
See MoreCanada: Guidance on intra-group services published
The Canada Revenue Agency (CRA) has published Transfer Pricing Memorandum (TPM)-15 regarding intra-group services and section 247 of the Income Tax Act on 13th February 2015. TPM-15 describes the CRA’s audit policy on some audit and tax issues
See MoreOECD publishes comments received on discussion draft on use of the profit split method
On 10 February 2015 the OECD published on its website comments received in response to the discussion draft issued on 16 December 2014 on profit splits in the context of global value chains. One consequence of the ever greater integration of MNEs
See MoreSlovenia: Government Announces of Tax Cash Register System
The government approved the introduction of a tax cash register system on 5 February 2015. The Act will be published in March 2015 and this system will improve revenue collection. The exact date of the introduction, together with the list of
See MoreNigeria: Penalty and interest rates for unpaid tax has approved
The Federal Inland Revenue Service (FIRS) has released the accepted penalty and interest rates to be applied for the year 2015 on 2nd February 2015 regarding taxes not paid within the given periods. The 15% interest rate is determined while the
See MoreSouth Africa: Transfer Pricing Adjustments Regarding Withholding Tax Obligations
Under the income tax act, section 31(3), South Africa provide that any adjusted amount for transfer pricing and thin capitalization purposes, prior to 1 January 2015, constituted a deemed loan. The adjusted amount plus interest deemed to have
See MoreTransfer Pricing Brief: January 2015
Australia Requirement for Transfer Pricing Documentation- Taxpayers with a high risk transfer pricing profile will be held to more stringent requirements. Transfer Pricing Audits Penalty in Cases of Adjustments-25% penalty applies
See MoreSpain: Modifies the transfer pricing legislation
In the “Corporate Income Tax Reform 2015” enacted under the Law 27/2014 the following transfer pricing rules are amended; Scope of related-party transactions - The ownership requirement for related parties is increased from 5% (1% in the
See MoreCanada: Customs Notice permits import duty refund claims on transfer pricing adjustments
Basically, Customs Notices are issued to inform clients about proposed changes to customs procedures. Customs Notice N-15-001 has been published by the Canada Border Services Agency (CBSA) for deleting an obstacle to file import duty refund claims.
See MoreSpain: Government Announces New Country-by-Country Reporting Obligations for MNEs
The Spanish government on 20 January 2015 announced that it will issue regulations, expected to be adopted in the first half of 2015, that will require country-by-country reporting by multinationals. The new regulations would enter into force on 1
See MoreFrance: Increases Transfer Pricing Documentation Penalties
France’s 2015 Finance Bill, enacted on December 29, 2014, increased the penalties applicable in cases of failure to comply with the French transfer pricing documentation rules. The newly defined penalty for a failure to produce transfer pricing
See MoreIceland: Final regulation on transfer pricing documentation
Accordance with the Regulation No. 1180/2014 the Ministry of Finance issued the final regulation on transfer pricing on 16 December 2014, which entered into force on 1 January 2015. The final regulation clarifies that the transfer pricing rules and
See MoreJapan: Honda Succeeds in Transfer Pricing Case
The Tokyo District Court in the case of: Heisei 23 (2011) gyou-u No. 164 ruled on 28 August 2014 that, in using the residual profit split method, the profits to be attributed should include the special tax benefits enjoyed by the Brazilian
See MoreSingapore: New Revised Transfer Pricing Guidelines for 2015
The Inland Revenue Authority of Singapore (IRAS) publishes revised transfer pricing (TP) guidelines on 6 January 2015. The 2015 TP Guidelines are generally in line with the OECD Transfer Pricing Guidelines (2010) as well as some relevant areas of
See MoreFrance: New Tax Laws Permit Sister Companies To Consolidate
France’s 2015 Finance Act and the Rectificative Finance Act for 2014 have entered into force. According to new law, the changes are below; New rules permitting sister companies to f for tax purposes. A reduction in the real estate
See MoreTransfer Pricing Brief: December 2014
Argentina Compliance-Decree 2103/2014 created a special unit to monitor cross-border trade and coordinate the work of the various government bodies to ensure the correct application of the law on international trade. Australia Transfer
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