Transfer Pricing Brief: March 2014
Austria Intangible property-From 1 March 2014 interest and royalty payments to certain related parties are not deductible for tax purposes if the recipient corporation is not subject to tax due to an exemption.Financial Services-From 1 March 2014
See MoreIndia shows decline in transfer pricing adjustments
The income tax department has estimated that the number of transfer pricing adjustments in 2014 so far has fallen by 14 percent by comparison to the previous year. This may indicate that taxpayers in India are becoming more aware of the transfer
See MoreNetherlands – Dutch taxpayer liable for Swiss captive subsidiary’s profits
A recent decision by a district Court in the Netherlands involved a Swiss captive insurance company that did not have any employees. The Court reached the decision that the tax authorities in the Netherlands were correct in levying tax on a related
See MoreIndia: Delhi Tribunal rules on transfer pricing aspects of intra group financing transactions
In India many transfer pricing cases are heard in the Courts. These decisions can provide clarification of the operation of the transfer pricing rules in India and can therefore give potential investors more certainty about the transfer pricing
See MoreEuropean law used in Turkish transfer pricing case
Turkey has taken a step towards improving the rights of taxpayers by implementing a decision of the European Court of Human Rights (ECHR) in a transfer pricing ruling. The transfer pricing case involved allegations by the tax administration that a
See MorePortugal: Necessary requirements for Financial Services
In Portugal, a restrictions on the deduction of interest has announced that effects from 2013. Net financial costs are only deductible up to the higher of EUR 1 million (EUR 3 million before 1 January 2014) or 30% of profit before depreciation, net
See MoreBulgaria: Information regarding Transfer Pricing Documentation
An Appendix 4 has been added to the return in accordance with commencing on the tax return for 2013, to be used by taxpayers to report related party transactions and transactions with entities situated in a jurisdiction with a preferential tax
See MoreUS: Important information regarding intra-group services
The regulations of Treasury and IRS final intercompany service were issued on 31 July 2009. Some permitted transfer pricing methods for services are similar to the OECD methods but the services cost method and shared services arrangements are also
See MoreOECD – Transfer pricing comparability data and developing countries
The OECD has prepared a paper in respect of transfer pricing comparability data and its use in developing countries. This is intended to find a response to concerns about the quality of comparable data available in developing countries. The lack of
See MoreNigeria – Companies requested to submit group transfer pricing documentation
In Nigeria the tax authority FIRS is asking taxpayers to send in transfer pricing documentation for the group to which they belong. Although there is no specific deadline they should do so as soon as possible and the documentation should be with the
See MoreMalaysia: increasing scrutiny of transfer pricing
The transfer pricing landscape in Malaysia continues to develop with the Malaysian tax authority becoming increasingly proactive and vigilant in examining the controlled transactions of multinational enterprises (MNEs). The intensity of tax audits
See MoreJapan: Increased focus on transfer pricing in tax audit
Transfer pricing audits in Japan are conducted separately from the general corporate tax audits, by a specialized transfer pricing audit team within the tax authority .The 2011 revision of the tax system in Japan included changes and clarifications
See MoreEU: JTPF presents comments received on the discussion paper on the Arbitration Convention
The Joint Transfer Pricing Forum (JTPF) held a meeting in Brussels on 6 March 2014at which the following items were discussed: – Information by the European Commission on ongoing issues; and – Arbitration
See MoreUruguay’s Tax Authority Reveals 2014 Targets
The Uruguayan tax authority (DGI) has recently revealed its 2014 audit targets. For 2014, the DGI indicated that it plans to conduct 1,350 tax audits in the year. This includes 90 audits for taxpayers whose turnover exceeds UYU50m (USD2.2m), and at
See MoreIndia: Tribunal finds reimbursed advertising expenses were at arm’s length
The Mumbai Bench of the Income tax Appellate Tribunal has upheld an administrative action by the Commissioner of Income tax, to reject a proposed transfer pricing adjustment for advertising expenses reimbursed by the taxpayer to its related
See MoreColombia: Information regarding comparable data range and segmented data uses
In accordance with the Regulatory Decree 3030 of December 2013, there is an economic link between the parties if the transaction is between a branch and home office, a transaction involving a permanent establishments, a related party transaction
See MoreTransfer Pricing Brief: February 2014
Argentina Transfer Pricing Requirements (TP)- TP requirements also apply to transactions carried out with individuals or legal entities located, organized or established in low or no tax jurisdictions. Australia Financial Services- On 16
See MoreSouth Africa – Transfer pricing, cross-border proposals in 2014 budget
South Africa’s 2014 budget contains proposals for changes to the transfer pricing rules and cross-border taxation. Among the transfer pricing and cross-border tax provisions in the 2014 budget are the following measures: Secondary adjustment for
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