Ukraine: Parliament Approves Tax Reform Plans
The Ukraine Parliament approved a package of laws on December 28, 2014, which significantly amend the system of taxation in Ukraine. Key changes are summarized below; General Provisions Number of taxes was decreased from 22 to 11 (including 2
See MoreAustralia: Practice Statement PS LA 2014/2 released by the Australian Taxation Office
The Australian Taxation Office (ATO) released guidance on what the ATO expects taxpayers to prepare in order to comply with the transfer pricing laws and manage related risks on 17 December 2014. According to guidance 25% penalty applies and
See MoreChina issues Circular Caishui [2014] No. 59 to extend the current preferential corporate income tax treatment
China’s Ministry of Finance, the State Administration of Taxation, Ministry of Commerce, Ministry of Science and Technology and National Development and Reform Commission jointly issued Circular Cai Shui no 59 On 8 October 2014, has extended the
See MoreAustralia: Taxation Ruling 2014/8 introduces by the Australian Taxation Office (ATO)
Taxation Ruling 2014/8 gives outlines on what needs to be included in the documentation if the taxpayer is to meet the standard of a "reasonably arguable position" and avoid penalties, and sets out five key questions for preparation of
See MoreKorea: Unilateral APA program introduced
A simplified APA (Advance Pricing Agreement) program is to be introduced from 2015 for the conclusion of unilateral APAs by manufacturers, wholesalers, retailers or service providers with revenue under KRW 50 billion. Applicants will be able to
See MoreSpain: Modified legislation on transfer pricing published
On 28 November 2014, Laws 26/2014 and 27/2014, which modify the most important Spanish tax laws were published in the Spanish Official Gazette. This new legislation will generally come into force on 1 January 2015. This new legislation modified in
See MoreIndia & Japan: First bilateral APA signed
The Central Board of Direct Taxes (CBDT) signed a bilateral Advance Pricing Agreement (APA) with a Japanese company on 19 December 2014. This is India’s first bilateral APA which has been signed for a period of 5 years. Moreover, CBDT was proud to
See MoreOECD Releases Discussion Draft on Revisions to Transfer Pricing Guidelines
A discussion draft was released by the OECD on 19 December 2014 setting out revisions to the OECD transfer pricing guidelines as a result of actions 8, 9 and 10 of the action plan on base erosion and profit shifting. These actions are quite closely
See MoreNigeria: First audit cycle under new transfer pricing regulations starts
The Federal Inland Revenue Service (FIRS) in Nigeria has built a Transfer Pricing Division on November 2013 that is accountable for the execution and administration of the Income Tax Transfer Pricing Regulations No.1 2012 (TP Regulations). This
See MoreFinland: Government Publishes Transfer Pricing Guidebook For Companies
The Finish Prime Minister’s Office published a guidebook on transfer pricing (TP) rules for Finnish companies on December 4, 2014. Finland wants to encourage companies to expand business activities abroad and to help foreign companies wanting to
See MoreSouth Africa: Revised Corporate Tax Returns Reflect REIT Reporting Requirements
The South Africa Revenue Service announced changes to the income tax return (ITR14) in respect of the 2014 year of assessment, to reflect rules for identifying a real estate investment trust (REIT). The changes are as follows; For the
See MoreArgentina: New decree creates for monitoring transfer pricing rules
Tax Authority has published Decree 2103/2014 on 17 November 2014, in order to 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
See MoreInformation regarding Transfer pricing reporting requirements in Czech Republic
The General Tax Directorate has released information regarding the new transfer pricing reporting requirements on its website and confirms that tax audits, the tax authorities will pay special attention to transactions with related parties and the
See MoreTransfer Pricing Brief: November 2014
Australia Transfer Pricing Rule-The reconstruction provisions are contained in section 815-130 ITAA 1997. TR 2014/6 gives guidance on identifying situations where the form of commercial or financial relations differs from the
See MoreIndia: Taxpayer’s use of the Resale Price Method for distribution activities Supported by the court
In the case of : CIT v. L’Oreal India Pvt. Ltd. (ITA No. 1046 of 2012 (7 November 2014), The Bombay High Court confirmed a tribunal decision that, the taxpayer’s use of the Resale Price Method (RPM) for purposes of determining the arm’s
See MoreCzech Republic: Burden of proof regarding investment incentives and transfer prices
The Supreme Administrative Court of the Czech Republic has issued a decision in a case regarding a company that took tax relief on the basis of some investment incentives and was needed to establish arm’s length prices due to its transaction with
See MoreSpain: EU Court Backs Spanish Tax Breaks For Foreign Acquisitions
Spain has won against European Union for tax breaks intended to help its companies buy stakes in foreign firms, where EU regulators' campaign against tax deals they view as illegal subsidies. The EU court has ruled in Spain's favor regarding
See MoreFrance: Tax Administration Publishes Guidelines On The Abridged Transfer Pricing Documentation
French tax administration published guidelines on the abridged transfer pricing documentation in the Official Bulletin for Public Finances Taxes on 6 November 2014. Legal persons established in France must be submitted in the French language to the
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