Greece: Transfer pricing obligations of acquiring company in case of merger
The Public Revenue Authority has published a legal document entitled "ΔΕΑΦΒ 1086197 ΕΞ 2016" on 2nd June 2016 for providing clarifications that the acquiring company is responsible for the submission of the relevant transfer pricing
See MoreAustria: Proposes legislation on Transfer Pricing documentation and CbC reporting
The Austrian Ministry of Finance (MoF) has published draft legislation to implement the Master File in line with the new OECD standard. The legislation includes a requirement to prepare a Master file, Local file(s), and CbCR. The new requirements
See MoreTransfer Pricing Brief: May 2016
Sweden: BEPS related compliance Master File information: The Swedish Tax Agency has submitted a proposal to the Swedish Government for new Transfer Pricing documentation like Master File. Under the current proposal, the Master File reporting
See MoreGermany: Ministry of Finance introducing CbCR, Master File and Local File
The German Ministry of Finance published a draft bill on 1 June 2016 to incorporate guidance on transfer pricing documentation and country-by-country (CbC) reporting into local legislation. The draft bill required multinationals with consolidated
See MoreAustria: Publishes Transfer Pricing Documentation draft Law
The Austrian Ministry of Finance (MoF) published the draft of the European Union (EU) Tax Amendment Act 2016 on 9 May 2016. The focus of this proposal is the draft of the new Austrian Transfer Pricing Documentation Law (TPDL). The new law serves as
See MoreUK: Consultation on secondary adjustments in transfer pricing legislation
On 26 May 2016 the UK has published a consultation document on the possible introduction of secondary adjustments into the UK transfer pricing legislation. This would in the opinion of the UK government help to ensure taxpayer compliance with the
See MoreAxiom Groupe conference on Transfer Pricing Excellence
The Axiom Groupe conference on Transfer Pricing Excellence was held in Barcelona on 19 and 20 May 2016. The conference included a workshop from the World Bank group. Some of the important issues coming out of the sessions are summarized
See MoreOECD: Report on the role of tax service providers
A report entitled “Rethinking Tax Services: The Changing Role of Tax Service Providers in SME Tax Compliance” was published during the meeting of the OECD's Forum on Tax Administration (FTA) on 9 to 11 May 2016. The report looks at the
See MoreBelgium would introduce Cbc reporting and transfer pricing documentation requirements
A draft law that would introduce country-by-country reporting and formal transfer pricing documentation requirements at present is in the process of being finalized in Belgium. Cbc reporting Belgium has proposed draft legislation to introduce the
See MoreNorwegian Government Issued its Proposal for Implementation of Country-by-Country Reporting
The Norwegian Government has sent its draft bill on the domestic Country-by-Country (CbC) reporting rules to the Norwegian tax authorities. As per the proposal, all multinational groups with annual consolidated group revenue equal to or exceeding
See MoreIndia: The Tribunal held that, no transfer pricing adjustment of AMP expenses
The Mumbai Bench of the Income-tax Appellate Tribunal in the case of: L’Oreal India Pvt. Ltd. v. DCIT , held that the tax officer must prove that the taxpayer’s real intention in incurring an advertising, marketing, and promotion (AMP)
See MoreATO published a Practice Statement for TP penalties in transition period
The Australian Taxation Office published a Practice Statement Law Administration 2016/2 (PS LA 2016/2) to deal with the application of transfer pricing penalties during the transition period between 1 July 2004 and 28 June 2013. During that period,
See MoreIndia: APA for earlier year may apply, determining “tested party”
Recently, the Delhi Bench of the Income-tax Appellate Tribunal (the Tribunal) in case of: Ranbaxy Laboratories Ltd. v. ACIT (ITA No. 196/Del/2013), held that overseas Associated Enterprises (AEs) being least complex entities in the transaction,
See MorePeru-New transfer pricing declaration forms
The tax authority (SUNAT) in Peru on 30 April 2016 published two new transfer pricing-related forms (Form No. 3530 & Form No. 3560). Form No. 3560 modifies and replaces the prior version of the electronic form No 1630. These new forms are to be
See MoreAustralia: Amended the Transfer Pricing Rules as per 2015 OECD Transfer Pricing Recommendations
Australia's transfer pricing legislation currently specifies that it be interpreted to achieve consistency with the OECD transfer pricing guidelines as last updated in 2010. The OECD's final report on Action Items 8-10 of the G20/OECD BEPS Action
See MoreDenmark: Plans for the introduction of alternative dispute resolution for TP cases
The Minister of Taxation announced on 2 May 2016, for transfer pricing cases they are planning for the introduction of alternative dispute resolution (ADR) system. The introduction of ADR is considered essential in order to assurance that transfer
See MoreSouth Africa: SARS introduced certain changes to the Income Tax Return for Companies (ITR14)
The South African Revenue Service (SARS) introduced certain changes to the Income Tax Return for Companies (ITR14) on 18 April 2016. Changes include the expansion of information required in relation to transfer pricing transactions. ITR14 increasing
See MoreSweden Proposes Implementation of BEPS 13
The Swedish Tax Agency (STA) has proposed to implement transfer pricing documentation and Country-by-Country (CbC) Reporting. As per the proposal, the Master File reporting obligations will be applicable to MNEs that have more than 250 employees and
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